District Court of Appeal of Florida July 18, 2001, No. 4D99-3825 (Smenner v. State)
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United States · · · 18-07-2001
PER CURIAM.
In State v. Harbaugh, 754 So.2d 691 (Fla.2000), the Florida Supreme Court held that, if prior convictions are elements of a crime, the prior convictions must be established by proof beyond a reasonable doubt.
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