California, United States of America
The following excerpt is from People v. Allen, C071390 (Cal. App. 2019):
It is true that while the record suggests multiple firearms were fired it does not disclose the order in which they were fired, which firearms caused the injury, or link a particular handgun to its shooter. But the missing information is unnecessary to a determination of proximate causation if the available evidence shows the defendant's act "set[] in motion a chain of events that produce[d] . . . the great bodily injury." (People v. Bland, supra, 28 Cal.4th at p. 335.) L.A.'s testimony established defendant fired a pistol and when the fusillade of shots ended seconds later, the victim had been hit. The defendant in his texts took credit for the shooting. The missing details identified by defendant do not preclude the jury's determination that defendant and perhaps others set in motion a chain of events that produced the victim's injury. The evidence supporting the enhancement was sufficient.
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