State v. Campa
In State v. Campa, 168 Ariz. 407, 814 P.2d 748 (1991), the court determined the use of prior convictions to establish felony DUI under the former A.R.S. 28-692.01(F) did not implicate double punishment concerns. Campa, 168 Ariz. at 411, 814 P.2d at 752.
The court reasoned that because the defendant's two prior felony convictions for driving offenses were not elements of the offense, "no double punishment considerations were implicated." Id.