LEBEN, J.
The sentence for theft may be enhanced to presumed prison—rather than probation—if the defendant has three or more prior felony-theft convictions. But a prior conviction used to enhance a penalty can't be counted in the criminal-history score, which affects the length of imprisonment.
When the district court sentenced Brian Williams for theft, Williams had four prior felony-theft convictions. The district court used three of the convictions...
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