A defendant’s sentence may be enhanced under the Persistent Felony Offender Statute when the second felony was committed before conviction of the first. Even if the defendant had no convictions at the time she committed her second felony, she may still be sentenced as a PFO. SCOMONT ruled that this was the clear precedent of State v. Hamm, 250 Mont. 123 (1991), and State v. Williamson, 218 Mont. 242 (1985), and declined to overturn those cases as “manifestly wrong.”
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