California, United States of America
The following excerpt is from The People v. Pryor, B220171, Los Angeles County Super. Ct. No. BA304366 (Cal. App. 2010):
is significant or substantial, not insignificant, trivial, or moderate: that is, great bodily injury. (See People v. Covino (1980) 100 Cal.App.3d 660, 668 [defining great bodily injury].) Based on the evidence presented, we cannot conclude that there is a reasonable probability that the jury would have returned a more favorable verdict if it had been instructed on simple assault and misdemeanor child abuse. (People v. Breverman, supra, 19 Cal.4th at p. 178.) Accordingly, any instructional error in failing to instruct on these two lesser included offenses was harmless here.
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