SERIOUS PHYSICAL INJURY
injury" is something more serious than mere physical injury, which is
defined as "impairment of physical condition or pain." It is more than
a minor or superficial injury. It is defined by statute as "physical
injury which creates a substantial risk of death, or which causes
serious disfigurement, serious impairment of health or serious loss or
impairment of the function of any bodily organ."
General Statutes § 53a-3 (4) (applies to Penal Code).
The forms of "serious physical injury" are not distinct, alternative
methods of committing a crime. The jurors need only determine
unanimously whether the victim suffered a serious physical injury; they
do not have to agree on which type of injury. State v. Wynter,
19 Conn. App. 654, 666, cert. denied, 213 Conn. 802 (1989).
injury does not need to be permanent. State v. Denson, 67 Conn.
App. 803, 811, cert. denied, 260 Conn. 915 (2002); see also State v.
Aponte, 50 Conn. App. 114, 121 (1998), rev'd in part on other
grounds, 249 Conn. 735 (1999) (medical testimony that injuries put
victim at risk of death at the time and temporarily impaired her
vision); State v. Rumore, 28 Conn. App. 402, 415, cert. denied,
224 Conn. 906 (1992) (unconciousness was a serious impairment); see also
State v. Rossier, 175 Conn. 204 (1978) (evidence of emotional
trauma precipitated by incident was insufficient to support conclusion
that serious physical injury had been inflicted).