California Supreme Court Justice Goodwin H. Liu has written a concurring statement to the high court’s denial of a petition for review in a case in which Div. Five of this district’s Court of Appeal held that 2022 amendments to the Penal Code, which favor the imposition of a midterm sentence and provide that an “enhancement” cannot be used to both add time and justify imposition of a high term, do not have any effect on the Three Strikes sentencing scheme.