What if a defendant has a prior judgment where they were convicted of two counts of two state jail felonies? Are there one or two convictions for enhancement?

a plain reading of 12.425(a) does not require anything about the convictions other than that they be final before the offense on trial. See Gowan, 18 S.W.3d at 307-08; Campbell, 49 S.W.3d at 876. A multi-count indictment results in two (or more) separate convictions. While the CCA noted this construction arguably produces an absurd result (because of the sequencing requirements stated in 12.425(b)) in Campbell, 49 S.W.3d at 877, it seems that must be what the Legislature intended.

This seems to be the outcome in the previous discussion of the issue State Jail Enhancements

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