California, United States of America
The following excerpt is from People v. Cooper, B283492 (Cal. App. 2018):
7. Contrary to defendant's argument, People v. Cole (1982) 31 Cal.3d 568 does not compel a different result. Cole considered section 12022.7, which governs personal infliction of great bodily injury. (Id. at p. 572.) It does not consider the term "use," which is dispositive in this case.
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