How have courts dealt with medical malpractice cases involving physical injuries?

wound near buttock and another suffered penetrating gunshot wound through thigh, but no evidence either victim sought or received medical treatment]; People v. Jaramillo (1979) 98 Cal.App.3d 830, 834-837 [child whose mother hit her with a stick, suffered swelling, bruises, multiple contusions, and pain the next day].)