olent" felony convictions imposed prior to the law's enactment in 1994 can be charged as strikes, People v. Kinsey, 47 Cal. Rptr. 2d 769, 775 (Ct. App. 1995), as may a defendant's equivalent convictions received in another jurisdiction, California Penal Code �� 667(d)(2), 1170.12(b)(2), and certain convictions a defendant received as a juvenile, California Penal Code �� 667(d)(3), 1170.12(b)(3). Fourth, there is no "washout" period after which prior qualifying convictions will no longer be counted as strikes.² People v. Martinez, 84 Cal. Rptr. 2d 638, 646 & n.9 (Ct. App. 1999) (citing Cal. Penal Code � 1170.12(a)(3)). Fifth, defendants with prior strikes who are convicted of current multiple felonies committed on different occasions must serve consecutive sentences. Cal. Penal Code �� 667(c)(6), 1170.12(a)(6); People v. Ingram, 48 Cal. Rptr. 2d 256, 264 (Ct. App. 1995) ("Since each felony count of which defendant currently stands convicted arises from separate residential burglaries, the mandatory minimum term of 25 years to life must be imposed consecutively for each count, for a minimum . . . term of 50 years."), disapproved on other grounds by People v. Dotson, 941 P.2d 56, 63 (Cal. 1997). Finally, a defendant sentenced to an indeterminate life sentence will not be eligible for parole until he has served his entire mandatory minimum term. Cervera, 16 P.3d at 181 (holding that a third-strike defendant's mandatory minimum term of 25 years may not be reduced with good-time credits).

B. Facts And Procedural History

According to the probation officer's presentence report, Andrade is a longtime heroin addict with a history of convictions for non-violent offenses. The report indicates that Andrade was convicted in 1982 of a misdemeanor theft

²The California Supreme Court has held, however, that judges have reviewable discretion to not consider, in the interest of justice, an otherwise qualifying conviction as a strike. People v. Superior Court (Romero), 917 P.2d 628, 647 (Cal. 1996).

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