People v. Cook (2015)

In People v. Cook (2015) 60 Cal.4th 922, a case which involved manslaughter with multiple victims, the Supreme Court held "that subdivision (g) of Penal Code section 12022.7 means what it says: Great bodily injury enhancements do not apply to a conviction for murder or manslaughter. A defendant convicted of murder or manslaughter who also commits crimes against other victims may be convicted of those additional crimes and, to the extent the sentencing laws permit, punished separately for them. But the sentence for manslaughter may not be enhanced for the infliction of great bodily injury as to anyone." (Cook, supra, 60 Cal.4th at p. 924 .) The Supreme Court went on to cite Beltran with approval and disapproved several cases that disagreed with Beltran, and allowed the imposition of section 12022.7 enhancements for victims other than the victim in the charged offense. (Cook, supra, at pp. 935, 939.)