Out-of-State Convictions and "Strict Conformity"

A number of statutes allow the State to enhance or aggravate a defendant's sentence based upon the existence of a prior felony conviction, while some require proof of a prior conviction as an element of the offense. What do you do, however, if the prior conviction is from another state? This presentation will address the "strict conformity" standard adopted by the Arizona Supreme Court to determine whether an out-of-state conviction can be used to enhance a defendant's sentence.