California, United States of America
The following excerpt is from People v. Boatman, A142348 (Cal. App. 2015):
"[W]hether the force used by the defendant was likely to produce great bodily injury is a question for the trier of fact to decide." (People v. Sargent (1999) 19 Cal.4th 1206, 1221.) Section 245 does not define "the means to be used as requisite to a conviction. Its language 'is a general and comprehensive term designed to embrace many and various means and forces.' " (People v. Pullins (1950) 95 Cal.App.2d 902, 904.) "That the use of hands or fists alone may support a conviction of assault 'by means of force likely to produce great bodily injury' is well established . . . ." (People v. Aguilar, supra, 16 Cal.4th at p. 1028.)
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