What is the test for establishing a great bodily injury finding where a shooting victim is shot in the back of the head with a single bullet wound?

"Proof that a victim's bodily injury is 'great' . . . is commonly established by evidence of the severity of the victim's physical injury, the resulting pain, or the medical care required to treat or repair the injury. [Citations.]" (People v. Cross (2008) 45 Cal.4th 58, 66.) However, "[a]lthough any medical treatment obtained by the victim is relevant to determining the existence of 'great bodily injury' [citation]," the statutory definition and relevant case authorities "do not require a showing of necessity of medical treatment." (People v. Wade (2012) 204 Cal.App.4th 1142, 1150, italics in original.) For example, in People v. Lopez (1986) 176 Cal.App.3d 460, the court upheld great bodily injury findings where one victim was shot in the right buttock and a second victim in the left thigh; there was no evidence either victim sought or received medical attention. (Id. at pp. 463-465.) In People v. Wolcott (1983) 34 Cal.3d 92, the court upheld the great bodily injury finding where the victim was shot in the calf and the bullet fragmented. The treating doctor removed one fragment but left the others to "work their way out naturally." The victim lost little blood, no sutures were required, and the victim went to work the next day. (Id. at p. 107.) Wolcott concluded the victim's "penetrating wounds" could not be "described as 'superficial' . . . ." (Id. at p. 108.)

"[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, supra, 45 Cal.4th at p. 64.)