California, United States of America
The following excerpt is from People v. Jackson, B264585 (Cal. App. 2018):
personally inflicts "great bodily injury" in the commission of the offense. "An examination of California case law reveals that some physical pain or damage, such as lacerations, bruises, or abrasions is sufficient for a finding of 'great bodily injury.' [Citations.]" (People v. Washington, supra, 210 Cal.App.4th at p. 1047 [comparing California and Illinois law for purpose of whether prior conviction was a strike under California law]; accord, People v. Escobar (1992) 3 Cal.4th 740, 750 [evidence sufficient to support jury finding of great bodily injury based on "extensive bruises and abrasions over the victim's legs, knees and elbows, injury to her neck and soreness in her vaginal area of such severity that it significantly impaired her ability to walk"].)
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