In People v. Woodhead (1987) 43 Cal. 3d 1002, the defendant was convicted of second degree burglary and committed to the Youth Authority. The Youth Authority rejected the placement, contending the defendant was ineligible because he had previously been convicted of a serious felony, and under Welfare and Institutions Code section 1732.5 "no person convicted of ... any ... serious felony" shall be committed to the Youth Authority. (Woodhead, supra, at p. 1006.) The California Supreme Court found the phrase "no person convicted of" ambiguous, noting the word "convicted" must be interpreted from its context. (Id. at p. 1008.) To resolve the ambiguity, the court looked to language from section 667, subdivision (a)(1), which, like Welfare and Institutions Code section 1732.5, had been added by Proposition 8. In section 667, subdivision (a)(1), the Legislature provided that a sentence enhancement applies to "any person convicted of a serious felony who previously has been convicted of a serious felony." Because the drafters of section 667 chose to describe in distinct terms those persons convicted of a serious felony and those who had previously been convicted of a serious felony, the court concluded the word "convicted" in Welfare and Institutions Code section 1732.5 referred to persons whose current conviction was a serious felony, and not to persons who had previously been convicted of a serious felony. (Woodhead, supra, 43 Cal. 3d at 1009-1010, 1014.)