What is the evidentiary sufficiency of a finding of great bodily injury in a sexual assault case?

Appellate courts have rejected similar challenges to the evidentiary sufficiency of a GBI finding. For example, in People v. Jaramillo (1979) 98 Cal.App.3d 830, 836, the defendant struck the victim repeatedly with a stick on different parts of her body. The court noted the "testimony and exhibits display that [the victim] suffered multiple contusions over various portions of her body and the injuries caused swelling and left severe discoloration on parts of her body. The injuries were visible the day after infliction to at least two lay persons at [the victim's] elementary school. Further, there was evidence [she] suffered pain as a result of her injuries . . . . [] A fine line can divide an injury from being significant or substantial from an injury that does not quite meet the description. Clearly it is the trier of fact that must in most situations make the determination. Here, while the issue might be close it appears that there were sufficient facts upon which the court could base its finding of great bodily injury and such a finding therefore will not be disturbed on appeal." (Id. at p. 836.) In People v. Sanchez (1982) 131 Cal.App.3d 718, the appellate court found sufficient evidence supported a GBI finding where the defendant grabbed the rape victim by the throat and choked her, slapped her face with an open hand and fist, and wrapped a belt around her neck, the victim suffered numerous bruises on her face, multiple superficial abrasions and

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lacerations on her back and neck, although none of the cuts or scratches required suturing.