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“Prior convictions for sentence enhancement purposes must be established by clear and convincing evidence.” ¶ 15 (App. 2004).

The State must prove a prior conviction by clear and convincing evidence and “submit positive identification establishing that the accused is the same person who previously was convicted, as well as evidence of the conviction itself.” ¶¶ 15-16 (App. 2004) (citation omitted).

¶6 The State must prove a prior conviction by clear and convincing evidence and admit “positive identification establishing that the accused is the same person who previously was convicted, as well as evidence of the conviction itself.” ¶¶ 15-16 (App. 2004) (citation omitted).

902; ¶ 18 (App. 2004) (“[C]ertified copies of the court records are proper, self- authenticated documents that are properly offered in support of an allegation of prior convictions.”).

Moreno-Medrano, 218 Ariz. at 354 ¶ 17 (citing, in order, and Carver, ).

¶ 15 (App. 2004) (“[P]rior convictions for sentence enhancement purposes must be established by clear and convincing evidence.”).

¶ 18 (2004) (citations omitted).

¶ 6 (2007) (explaining that “[w]hen a defendant’s sentence is enhanced by a prior conviction, the existence of the conviction must be found by the court”); ¶ 15 (App. 2004) (holding that “prior convictions for sentence enhancement purposes must be established by clear and convincing evidence”).

6 STATE v. EATON Decision of the Court convicted, as well as evidence of the conviction itself.” ¶ 16 (App. 2004).

“Prior convictions for sentence enhancement purposes must be established by clear and convincing evidence.” ¶ 15 (App. 2004).

P. 31.13(c); –16, ¶ 18 (App. 2004).

In State v. Cons, this court noted amending a sentencing allegation to conform to the evidence was not error, because it “did not so alter the nature of the allegation that Cons was deprived of the notice to which he was entitled.” ¶ 6 (App. 2004).

It is the State’s burden to prove the existence of a defendant’s prior convictions by clear and convincing evidence, ¶ 15 (App. 2004), and we review de novo a trial court’s determination that a prior conviction constitutes an historical prior felony, ¶ 8 (App. 2001).

In the analogous situation of sentence enhancement in adult prosecutions based on prior felony convictions, the state must “‘submit positive identification establishing that the accused is the same person who previously was convicted.’”

¶30 “The charges in an indictment and the allegations of [dangerousness] are not procedural or substantive equivalents.” 2

“[P]rior convictions for sentence enhancement purposes must be established by clear and convincing evidence.” ¶ 15

is not sufficient evidence”); , (name, detailed description, and prison photographs sufficient proof of prior felony); , (matching name, date of birth, and signature sufficient evidence of prior conviction); , (identification by name, date of birth, fingerprint, and recognition by trial judge “was overwhelming evidence”); , (unusual name, presence within Maricopa or Pinal County, and “comparable” description to that of prev

P. 31.13.(c)(1)(vi) (opening brief must contain citations to record and argument for each issue raised); , (failure to develop argument properly in opening brief results in waiver of issue on appeal).