California, United States of America
The following excerpt is from People v. Moon, F069168 (Cal. App. 2017):
" 'Great bodily harm refers to significant or substantial injury and does not refer to trivial or insignificant injury.' [Citation.]" (People v. Cortes (1999) 71 Cal.App.4th 62,
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80.) For felony punishment under subdivision (a) of section 273a, "there is no requirement that the actual result be great bodily injury." (People v. Jaramillo, supra, 98 Cal.App.3d at p. 835.) Rather, the circumstances or conditions surrounding the abuse must make such harm likely.
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