People v. Park, 56 Cal. 4th 782

Park pleaded guilty in 2003 to felony assault with a deadly weapon (Pen. Code, § 245, subd. (a)(1)); the court suspended imposition of sentence and placed him on probation.
In 2006, the prior offense was reduced to a misdemeanor under § 17, subd. (b)(3) and later dismissed under § 1203.4, subd. (a)(1).
In a subsequent prosecution, Park was convicted of assault with a firearm and related offenses, with prior serious felony allegations admitted but the court had stated the prior offense was reduced to a misdemeanor.
Park received a 24-year total sentence, including a five-year enhancement under § 667(a) based on the prior serious felony conviction.
The Court of Appeal affirmed the five-year enhancement; the Supreme Court granted review to decide the effect of § 17(b)(3) reductions on § 667(a) eligibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a wobble r v. 17(b)(3) reduction to a misdemeanor prevents § 667(a) from applying.	People argued the prior assault remained a serious felony.	Park argued the reduction to a misdemeanor erased the prior felony status.	No; § 667(a) does not apply when the wobble is reduced to a misdemeanor under § 17(b)(3).
What is the effect of § 1203.4 dismissal on use of the prior conviction for § 667(a) enhancement.	Prosecution relied on § 1203.4 to preserve the prior felony status for enhancement.	Dismissal under § 1203.4 does not resurrect the prior felony status.	§ 1203.4 does not override § 17(b)(3); prior wobblers reduced to misdemeanor are not felonies for § 667(a).
Do the voters’ intents in Prop. 8 and related constitutional provisions override § 17(b)(3) when applying § 667(a)?	Prop. 8 intends enhanced punishment for prior felonies regardless of later reductions.	No repeal by implication; § 17(b)(3) remains controlling absent explicit contrary intent.	No implied repeal; § 17(b)(3) governs; prior wobblers reduced to misdemeanors cannot support § 667(a).
Does Three Strikes interact with § 17(b)(3) reductions in determining sentence enhancements?	Three Strikes could still apply given prior conviction status.	Three Strikes status depends on the date of prior conviction and its final classification.	Three Strikes still doubles the current sentence; § 17(b)(3) does not convert prior status for § 667(a).

Banks v. State, 53 Cal.2d 370 (Cal. 1959) (wobbler reduced to misdemeanor precludes later use as prior felony for enhancements when sentence imposed otherwise)
Feyrer v. Superior Court, 48 Cal.4th 426 (Cal. 2010) (discusses suspension of imposition and probation; limits of § 17(b) interaction with other statutes)
In re Anderson, 69 Cal.2d 613 (Cal. 1968) (reentry of probation impact on felony/misdemeanor classification)
People v. Crowson, 33 Cal.3d 623 (Cal. 1983) (defendant may appeal legal question of prior felony status despite admission)
People v. West, 154 Cal.App.3d 100 (Cal. Ct. App. 1984) (interprets § 667(a) and prior conviction definitions)
People v. Camarillo, 84 Cal.App.4th 1386 (Cal. Ct. App. 2000) (limits on applying § 667(a) when wobblers reduced under § 17(b))
Perez v. Superior Court, 38 Cal.App.4th 347 (Cal. Ct. App. 1995) (historical context of § 17 and wobblers)