California, United States of America
The following excerpt is from People v. Czahara, 203 Cal.App.3d 1468, 250 Cal.Rptr. 836 (Cal. App. 1988):
During deliberations, the jury asked the court whether or not the transferred intent rule applied to the allegations of intentional infliction of great bodily injury. The court answered that it did apply. The great bodily injury enhancements require the state to prove a specific intent to inflict injury. (Pen.Code, 12022.7; People v. Simpson (1987) 192 Cal.App.3d 1360, 1365-1367, 237 Cal.Rptr. 910.) The court's answer to the jury's question was incorrect for the same reasons as was the transferred intent instruction on attempted murder.
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