California, United States of America
The following excerpt is from People v. Kim, B259869 (Cal. App. 2016):
"'"Serious bodily injury" and "great bodily injury" are essentially equivalent elements.' [Citation.]" (People v. Burroughs (1984) 35 Cal.3d 824, 831, overruled on another ground in People v. Blakeley (2000) 23 Cal.4th 82, 88-89; see also People v. Moore (1992) 10 Cal.App.4th 1868, 1871 ["'serious bodily injury,' as required for felony battery [ 243, subd. (d)], is essentially equivalent to or synonymous with 'great bodily injury' for the purpose of a 'serious felony' sentence enhancement [ 1192.7, subd. (c)(8)]"].)
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