People v. Sasser, 61 Cal. 4th 1

Defendant Darren Sasser was convicted of multiple forcible sex felonies and had one prior serious/strike conviction; trial court imposed both indeterminate One Strike/Habitual Sexual Offender terms and an alternative determinate Three Strikes-based sentence.
On remand the court imposed seven determinate doubled terms (Three Strikes §667(e)(1)) of 17 years each (double middle term plus a 5-year prior serious felony enhancement) as part of a stayed 229-years-to-life alternative sentence.
Sasser appealed, arguing the five-year prior serious felony enhancement (§667(a)(1)) should be applied only once to the aggregate determinate portion, not to each determinate term. The Court of Appeal affirmed. The Supreme Court granted review.
The legal question required reconciling the Determinate Sentencing Law (§1170.1), the forcible sex offense consecutive-term statute (§667.6(c)), the prior serious felony enhancement (§667(a)(1)), and the Three Strikes scheme (§667(b)–(i)).
The Supreme Court held that enhancements based on prior convictions are status-based and, under §1170.1, are added once to the determinate aggregate — thus the five-year enhancement may be applied only once to the determinate portion of Sasser’s second‑strike sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the §667(a)(1) five-year prior serious felony enhancement may be added to each determinate term in a second‑strike sentence or only once to the determinate aggregate	AG: Three Strikes policy supports applying §667(a)(1) to each count to increase punishment for recidivism	Sasser: Under §1170.1 and People v. Tassell, prior‑conviction enhancements are status‑based and should be added once to aggregate determinate terms	Held: §1170.1 governs application of prior‑conviction enhancements to determinate terms; the §667(a)(1) enhancement applies only once to the determinate portion
Whether §667.6(c) (full consecutive terms for forcible sex offenses) displaces §1170.1’s rule treating prior‑conviction enhancements as a single aggregate addition	AG: Because sentencing here was under Three Strikes and §667.6(c) allows full consecutive terms, multiple §667(a)(1) enhancements are permissible	Sasser: §667.6(c) replaces only the principal/subordinate term calculation, not the §1170.1 rule on prior‑conviction enhancements	Held: §667.6(c) replaces the method for calculating consecutive base terms but does not alter §1170.1’s rule that prior‑conviction (status‑based) enhancements are added once; Tassell controls

People v. Tassell, 36 Cal.3d 77 (Tassell establishes that under §1170.1 prior‑conviction enhancements are status‑based and added once to the aggregate determinate sentence)
People v. Nguyen, 21 Cal.4th 197 (Two‑strikes doubling incorporates §1170.1 principal/subordinate methodology for determinate terms)
People v. Williams, 34 Cal.4th 397 (Tassell’s rule does not apply to multiple indeterminate third‑strike terms; distinguishes determinate vs indeterminate contexts)
People v. Gutierrez, 28 Cal.4th 1083 (confirms Tassell’s rule applies to §667(a) enhancements)
People v. Belmontes, 34 Cal.3d 335 (discusses §667.6(c) as an alternative sentencing scheme for forcible sex offenses)