O'CONNELL, Presiding Judge.
In this case of first impression, we conclude that a prior plea-based misdemeanor conviction, obtained without benefit of counsel but for which no incarceration was imposed, may be used in a subsequent criminal prosecution for purposes of sentence augmentation.
In 1987, defendant pleaded guilty to the misdemeanor of second-degree retail fraud, M.C.L. § 750.356d(1); M.S.A. § 28.588(4). Acting without counsel, defendant...
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