California, United States of America
The following excerpt is from State v. Guzman, 77 Cal.App.4th 761, 91 Cal.Rptr.2d 885 (Cal. App. 2000):
Section 12022.7 is a legislative attempt to punish more severely those crimes that actually result in great bodily injury. (People v. Parrish (1985) 170 Cal.App.3d 336, 344.) It applies except where serious bodily injury is already an element of the substantive offense charged. (Ibid.)
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