California, United States of America
The following excerpt is from The People v. Bautista, F058178, No. F09900642 (Cal. App. 2011):
Neither party has cited, nor has our research located, any case that specifically holds that great bodily injury may be inflicted only on a living person. Nor has any case been cited or located where great bodily injury was inflicted on a corpse. Perhaps this is because "'The term "great bodily injury" has been used in the law of California for over a century without further definition and the courts have consistently held that it is not a technical term that requires further elaboration.' [Citation.]" (People v. Maciel (2003) 113 Cal.App.4th 679, 686.)
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