The Court of Appeal holds that SB 567‘s amendments to PC 1170(b), which created a presumption in favor of the middle term and entitle a defendant to a bifurcated trial on aggravating circumstances, did not impose a pleading requirement for aggravating circumstances. PC 1170.1(e) applies only to “enhancements,” and “[a]n upper term is still a base term and not an enhancement under section 1170.1.”
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