California, United States of America
The following excerpt is from In Re Moses C., B225785 (Cal. App. 2011):
"Cases have construed 'great bodily injury' to be the same as 'serious bodily injury.' [Citations.]" (People v. Chaffer (2003) 111 Cal.App.4th 1037, 1042; accord People v. Arnett (2006) 139 Cal.App.4th 1609, 1613 [stating that numerous courts have recognized that the terms have substantially the same meaning].) Great bodily injury, therefore, is an element of the substantive offense of battery with serious bodily injury.
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