In Gargliano v. State, 334 Md. 428, 639 A.2d 675 (1994), the defendant sold cocaine to an undercover police officer in December 1989, January 1990, and on December 21, 1990. He was arrested for the first two sales on December 21, 1990, and subsequently convicted of two counts of distribution of cocaine. Before the defendant went to trial for the December 21, 1990 sale, the State advised of its intent to seek an enhanced sentence based on the two earlier cocaine sales. As the Court noted, the defendant "committed the December 1990 offense before he was convicted - indeed, before he was even arrested - for either of the two prior sales." Gargliano, 334 Md. at 432. In interpreting 286(c), the Court followed the majority rule among the states that "the prior conviction used to enhance a sentence must precede the commission of the principal offense." 334 Md. at 445-46 Because the defendant's convictions on the December 1989 and January 1990 sales did not occur prior to December 21, 1990, sentencing enhancement was improper. The Gargliano Court went on to say, however: "Where, as here, the defendant has not been convicted of an earlier offense, and thereby warned about the enhanced consequences of future criminal conduct, prior to the commission of the principal offense, the imposition of an enhanced penalty is not warranted." 334 Md. at 445 . The Court of Appeals recognized that the phrase "if the person previously has been convicted" is not clearly defined in the statute or otherwise discussed anywhere in legislative history. See Gargliano, 334 Md. at 438-42. Because the dueling interpretations offered by the State and the defendant in that case were both reasonable, the Court "looked beyond the words of the statute . . . to other evidence of legislative intent to determine which interpretation of the two best furthers the legislative object or goals." Id. at 439. Consequently, the Court analyzed the meaning of the proviso "if the person previously has been convicted" in the context of the problem it was enacted to address. In construing Maryland enhanced penalty statutes similar to 286(c), we have found that such statutes were enacted with the purpose of identifying defendants who have not reformed their behavior after prior convictions and incarcerating such defendants for a longer period than would otherwise be applicable in order to protect the community and deter others from similar behavior. The means for achieving such deterrence is the provision of fair warning to previous offenders that if they continue to commit criminal acts after having had the opportunity to reform after one or more prior contacts with the criminal justice system, they will be imprisoned for a considerably longer period of time than they were subject to as first offenders. . . . We find that the Legislature had the same intent in enacting 286(c). An enhanced penalty statute will best deter future criminal conduct when the defendant is made aware that the subsequent commission of criminal acts will be more harshly punished. Where, as here, the defendant has not been convicted of an earlier offense, and thereby warned about the enhanced consequences of future criminal conduct, prior to the commission of the principal offense, the imposition of an enhanced penalty is not warranted. /8Id. at 444-45.) In sum in Gargliano v. State, a State trooper purchased cocaine from Gargliano in December 1989 and again in January 1990. Id. at 431, 639 A.2d 675. After yet a third transaction in December 1990, he arrested Gargliano, who was then charged with all three sales. Id. at 431-32. The State initially brought Gargliano to trial on charges arising from the first two sales; Gargliano was convicted in April 1991 of two counts of drug distribution. Id. at 432. Thereafter, in June 1991, prior to Gargliano's trial for the third offense, the State notified him of its intent to seek enhanced punishment with regard to the December 1990 offense, based on his two convictions in April 1991. Id. Gargliano was subsequently convicted in September 1991 for the third drug distribution offense. Id. Noting that he had committed the third offense before he was arrested or convicted for either of the two prior incidents, Gargliano argued at sentencing that the enhanced penalty mandated by Article 27, 286(c) should not apply to a defendant "who had neither been charged with nor convicted of a prior offense at the time the principal offense was committed." Id. The trial court disagreed. It ruled that 286(c) applied "whenever a prior conviction exists at the time of sentencing on the principal offense." Id. Therefore, it imposed a mandatory term of ten years, without parole. Id. On appeal, the Court was asked "to determine whether the enhanced penalty mandated by 286(c) is triggered when a defendant is convicted of a prior offense after the commission of, but before sentencing on, the principal offense upon which the enhanced penalty is sought." Id. at 431. It held that "the mandatory sentence prescribed by 286(c) may be imposed only where the conviction for a prior offense precedes the commission of the principal offense...." Id. The Court said: "We hold today that a conviction obtained after the commission of the principal offense does not trigger the imposition of a statutory enhanced penalty...." Id. at 449. In reaching its conclusion, the Court of Appeals discussed the structure of 286, noting that subsections (c), (d), and (e) "form a comprehensive scheme of graduated mandatory penalties for repeat offenders." Id. at 440. But, with respect to whether a conviction for the predicate offense must precede the commission of the principal offense, the Court regarded as ambiguous the statutory phrase "previously has been convicted." Id. at 438. Reviewing the legislative history of 286, it noted that "the phrase 'has previously been convicted' was not defined in 286 as it existed in 1982," when the legislation was enacted, or when it "was amended in 1988 to provide for even greater penalties for third and fourth convictions." Id. at 439-40. As the Court pointed out, subsection (c) did "not identify whether the prior conviction must be previous to the principal offense or merely previous to the sentencing for the enhanced penalty to apply." Id. at 434-35. In its view, the proper interpretation of the phrase "previously has been convicted" turned on "whether the statute was intended to apply only to defendants who fail to reform their behavior after a prior conviction or whether it was intended to apply to all defendants who amass multiple convictions." Id. at 438. The Court said, id. at 442: "The clear import of the language used throughout 286 is that the Legislature sought to impose more stringent penalties on certain offenders who repeatedly persist in a pattern of criminal conduct. From the sparse legislative history available, however, we cannot conclusively determine whether the General Assembly sought to subject all individuals who commit multiple offenses to the enhanced penalty or whether it sought to impose the statutory penalty only upon the narrower class of persons who have not responded to the restraining influence of conviction and punishment and thereafter continue to commit criminal acts."