Footnotes

Footnotes
1
Markus Dubber, "The Unprincipled Punishment of Repeat Offenders: A Critique of California's Habitual Criminal Statute," 43 Stan. L. Rev. 193 (1990).
2
18 U.S.C. §924(e).
3
"Prosecutors to Apply 'Three Strikes' Law," Seattle Times, March 29,1994 at AB2.
4
"Three Strikes' Robber Sentenced to Life Term," Seattle Times, October 8, 1994 at A8.
5
"How three strikes' law is used across the state: Prosecutors exercise differing degrees of discretion in charging those liable for long sentences," San Francisco Examiner, August 8, 1994 at A7.
6
Id.
'"Three Strikes' Inmate Is Accused In Rape At Jail," Los Angeles Times, July 26, 1994 at B1.
7
"Pizza Case Unlikely Focus Of Three Strikes' Debate," Los Angeles Times, September 18, 1994 at B1.
Id.
8
Supra, San Francisco, April 8, 1994 at A7.
9
"Convicted Robber Gets 'Third Strike,'" Seattle Times, November 11, 1994 at B2
10
Id.
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