California, United States of America
The following excerpt is from People v. Seals, 80 Cal.Rptr. 710 (Cal. App. 1969):
In People v. Bradbury (1907) 151 Cal. 675, 676-677, 91 P.497, the court said: 'The 'violent injury' here mentioned is not synonymous with 'bodily harm,' but includes any wrongful act committed by means of physical force against the person of another, even although only the feelings of such person are injured by the act. The term 'violence' as used here is synonymous with 'physical force,' and in relation to assaults the two terms are used interchangeably. * * * 'The kind of physical force is immaterial; * * * it may consist in the taking of indecent liberties with a woman, or laying hold of and kissing her against her will.' * * *' (Accord: People v. Flummerfelt (1957) 153 Cal.App.2d 104, 106, 313 P.2d 912.)
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