What is the test for establishing a "pattern of criminality" in a criminal case?

California, United States of America


The following excerpt is from People v. Tackett, F062188 (Cal. App. 2012):

In determining whether such a "'pattern of criminality'" exists, the court may consider "prior convictions, [the defendant's] performance on probation or parole, and the circumstances of the present offense." (See People v. Jeffrey (2006) 142 Cal.App.4th 192, 196.)

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