California, United States of America
The following excerpt is from People v. Mauricette, E071959 (Cal. App. 2020):
As defendant also argues, "the terms 'serious bodily injury' and 'great bodily injury' have been described as '"'essential[ly] equivalent'"' [citation] and as having 'substantially the same meaning' [citation]. [Citations.]" (People v. Santana (2013) 56 Cal.4th 999, 1008, and cases cited.) Surely every bodily injury that "serious[ly] impair[s] [one's] physical condition," so as to be serious bodily injury, is also "significant," so as to be great bodily injury. Thus, if there is any daylight between the two concepts at all, great bodily injury is necessarily included in serious bodily injury.
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