California, United States of America
The following excerpt is from People v. Almeida, C078495 (Cal. App. 2017):
"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 (2012) 210 Cal.App.4th 1042, 1047.) Extensive bruising and swelling suffices to show great bodily injury. (People v. Jaramillo (1979) 98 Cal.App.3d 830, 836-837.)
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