The term "great bodily harm" forms the basis of many statutory definitions regarding the implied use of deadly or lethal force. Regrettably, statutes remain obscure as to what actual types of injuries constitute a judgment that great bodily harm has occurred. A search of case law shows that most determinations of great bodily harm are decided on a case-by-case basis, left up to a judge or jury to evaluate and declare.
Some examples of great bodily harm cited by the court include:
1. scarring2. permanent disfigurement3. broken bones4. Extended hospital stays (in one case "extended" was meant to mean overnight.
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