I think if each criminal act resulted in a separate conviction, then three strikes can apply. But I think if you go on a milk theft spree (over some period of t

I think if each criminal act resulted in a separate conviction, then three strikes can apply. But I think if you go on a milk theft spree (over some period of time keep stealing a gallon of milk from a bunch of different stores), when they catch you, you would likely be charged with multiple counts of milk theft and get "Strike 1" for the conviction. (also ignoring that stealing milk probably doesn't trigger the three-strikes rule.)