Tag Archives: GBI


The Huge Impact of A Tiny Two-Letter Word
October 15th, 2020

In this March 10, 2020 post FORECITE discussed the CALCRIM instructions which define great bodily injury as a “significant or substantial physical injury … that is greater than minor or moderate harm.” The post suggested, in reliance on People v. Medellin (2020) 45 Cal.App.5th 519, 533- 535 that — as argued by the prosecutor in […]


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Reviewing Court Reverses Conviction and Enhancement Due to CALCRIM’s Erroneous Definition of Great Bodily Injury — Over 40 CC Instructions Potentially Affected
March 10th, 2020

People v. Medellin (2020) 45 Cal.App.5th 519, 533- 535 concluded that the CALCRIM definition of “great bodily harm” [GBI] in CC 875 and CC 3160 erroneously allowed the prosecutor to argue and the jury to find GBI based on either greater than minor harm or greater than moderate harm. This “alternate theory error” resulted in […]


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GBI: Intent To Inflict GBI Not Required
May 30th, 2014

People v. Poroj (2011) 190 Cal. App. 4th 165, 168, upheld CC 3160, finding that the instruction correctly explained that the enhancement for personally inflicting great bodily injury in PC § 12022.7, “does not require a showing of intent to inflict GBI, separate or apart from the intent required to commit the felony or attempted […]


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