California, United States of America
The following excerpt is from People v. Balli, H045832 (Cal. App. 2020):
accomplice), because "great bodily injury, as defined in section 12022.7, is an element of the crime of battery under section 243, subdivision (d)." (People v. Hawkins (1993) 15 Cal.App.4th 1373, 1376.)
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