What is the test for a finding of personal infliction of great bodily injury?

facts upon which a determination depends. [Citation.] We resolve neither credibility issues nor evidentiary conflicts; we look for substantial evidence. [Citation.]' [Citation.] A reversal for insufficient evidence 'is unwarranted unless it appears "that upon no hypothesis whatever is there sufficient substantial evidence to support"' the jury's verdict." (People v. Zamudio (2008) 43 Cal.4th 327, 357; accord, People v. Manibusan (2013) 58 Cal.4th 40, 87.)

b. Substantial evidence supports the jury's finding Hachem personally inflicted great bodily injury

Section 12022.7, subdivision (a), provides a three-year enhancement for "[a]ny person who personally inflicts great bodily injury on any person other than an accomplice in the commission of a felony or attempted felony . . . ." A defendant "need not be the sole or definite cause of a specific injury" to support a finding he or she personally inflicted great bodily injury. (People v. Modiri (2006) 39 Cal.4th 481, 486.) In the context of a group beating, personal infliction of great bodily injury may be found "if defendant personally applied force to the victim, and such force was sufficient to produce grievous bodily harm either alone or in concert with others." (Id. at p. 497.) In group beating cases "the evidence is often conflicting or unclear as to which assailant caused particular injuries in whole or part. Thus, . . . those who participate directly and substantially in a group beating should not be immune from a personal-infliction finding for the sole reason that the resulting confusion prevents a showing or determination of this kind."¹⁰ (Id. at pp. 496-497.) Nonetheless, a defendant is not responsible for

Page 7