What is the test for "physical injury" in a sexual assault case?

"Physical injury," means "impairment of physical condition or substantial pain." Penal Law 10.00(9). This element can be sufficiently pled even in cases where the accusatory instrument describes only an act of violence and an injury, or even violence alone, but does not specifically allege that the violence caused the complainant substantial pain. In these cases, the instrument is sufficient as long as it alleges an act of violence that is sufficiently extreme to permit a reasonable inference that the violence was "an experience that would normally be expected to bring with it more than a little pain." People v. Chiddick, 8 N.Y.3d 445, 447, 834 N.Y.S.2d 710, 866 N.E.2d 1039 (2007).