California, United States of America
The following excerpt is from People v. Lopez, G056130 (Cal. App. 2019):
In his opening brief, Lopez challenges the jury's findings on this issue by stating: "There was absolutely no expert medical evidence to support the claim." No such evidence, however, was required to establish great bodily injury or serious bodily injury. Not even nonexpert evidence of medical treatment is required, as explained in People v. Wade (2012) 204 Cal.App.4th 1142, 1149-1150: "Although any medical treatment obtained by the victim is relevant to determining the existence of 'great bodily injury' [citation], the statutory definition . . . do[es] not require a showing of necessity of medical treatment. Nor are we aware of any case authority imposing such a requirement. Accordingly, our construction of 'serious bodily injury' is consistent with the definition of 'great bodily injury.'"
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