California, United States of America
The following excerpt is from People v. Berkley, F060201, Super. Ct. No. VCF230651 (Cal. App. 2011):
People v. Hale (1999) 75 Cal.App.4th 94, 108 [broken and smashed teeth, split lip, and cut under victim's eye were sufficient evidence of great bodily injury]; People v. Jung (1999) 71 Cal.App.4th 1036, 1042 ["Abrasions, lacerations, and bruising can constitute great bodily injury"].)
"[D]etermining whether a victim has suffered physical harm amounting to great bodily injury is not a question of law for the court but a factual inquiry to be resolved by the jury. [Citations.] '"A fine line can divide an injury from being significant or substantial from an injury that does not quite meet the description."' [Citations.] Where to draw that line is for the jury to decide." (People v. Cross (2008) 45 Cal.4th 58, 64.)
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