State v. Thompson (2001)

In State v. Thompson, 200 Ariz. 439, 27 P.3d 796 (2001), the Court construed the phrase "historical prior conviction" in 13-604(V) to mean that "the conviction on the prior offense must precede the conviction on the present offense." Thompson, 200 Ariz. 439, P 6, 27 P.3d at 798. The court also noted that "one is convicted when there has been a determination of guilt by verdict, finding, or the acceptance of a plea." Id. P 7. The court further explained that enhancement under 13-604 is not possible "when felonies are tried together." Id. P 9.