What is the test for making a contention that an enhancement is not statutorally applicable to a crime?

An appellant must make each contention under a separate heading in his opening brief. (See Cal. Rules of Court, rule 8.204(a)(1)(B); Opdyk v. California Horse Racing Bd. (1995) 34 Cal.App.4th 1826, 1830, fn. 4 [an appellant must present each point separately in the opening brief under an appropriate heading, showing the nature of the question to be presented and the point to be made; failure to do so may be deemed a forfeiture of the argument].) Here, a contention that an enhancement was not statutorily applicable to an offense is different from a contention that the evidence was insufficient

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