The question is not firmly settled under Florida law.
Wheeler v. State, 203 So. 3d 1007 addresses the issue w.r.t. Fla. Stat. §827.01(2), now §827.03(1)(a)3 and the crime of aggravated child abuse, which depends on causing "great bodily harm, permanent disability, or permanent disfigurement". The court notes that the chapter does not define "great bodily harm", but they also note that the same term is used in §784 – where as you observed it is likewise undefined. The courts take the term to mean the same thing in both cases. Calling on previous case law, they observe that GBH is
"distinguished from slight, trivial, minor, or moderate harm, and as
such does not include mere bruises as are likely to be inflicted in
simple assault and battery." T.W. v. State, 98 So.3d 238, 243 (Fla.
4th DCA 2012); see also Brown v. State, 86 So.3d 569, 571-72 (Fla. 5th
DCA 2012); Gordon v. State, 126 So.3d 292, 295 (Fla. 3d DCA 2011);
Smith v. State, 969 So.2d 452, 455 (Fla. 1st DCA 2007)
Thus
[t]he state "must prove more than that the victim suffered some harm"
Smith v. State, 175 So.3d 906
Consequently, the jury instruction for §775.087(2), related to discharging a firearm in the commission of a crime, states
“Great bodily harm” means great as distinguished from slight, trivial,
minor, or moderate harm, and as such does not include mere bruises.
does not include a case where
The victim suffered no injury and testified that it only stung when
she was struck with the broomsticks
nor does it include scratches, swelling, and puncture mark, but it does include a beating where a victim's
lips were "the size of a banana ... [and] his head was the size of a
basketball." D.C.'s face was so swollen that his mother did not
recognize him the next morning.
It is not hard to imagine unclear cases between puncture marks and ... swellings? It's interested to note that in one case, minor swelling is dismissed but massive swelling is taken to be great bodily harm.
Courts might appeal to a dictionary, such as Merriam-Webster's legal dictionary
physical injury suffered by the victim of a violent crime that causes
a substantial risk of death, extended loss or impairment of a body
part or function, or permanent disfigurement : physical injury that is
more serious than that ordinarily suffered in a battery
which is a bit problematic since the crime you are interested in is a battery.
Minnesota defines these terms, but makes a three-way distinction in types of bodily harm:
"Bodily harm" means physical pain or injury, illness, or any
impairment of physical condition.
"Substantial bodily harm" means bodily injury which involves a
temporary but substantial disfigurement, or which causes a temporary
but substantial loss or impairment of the function of any bodily
member or organ, or which causes a fracture of any bodily member.
"Great bodily harm" means bodily injury which creates a high
probability of death, or which causes serious permanent disfigurement,
or which causes a permanent or protracted loss or impairment of the
function of any bodily member or organ or other serious bodily harm.
Washington also has a 3-way classification for child abuse, repeated for general crimes:
(2)(a) "Bodily injury" means physical pain or injury, illness, or an
impairment of physical condition;
(b) "Substantial bodily harm" means bodily injury which involves a
temporary but substantial disfigurement, or which causes a temporary
but substantial loss or impairment of the function of any bodily part
or organ, or which causes a fracture of any bodily part;
(c) "Great bodily harm" means bodily injury which creates a high
probability of death, or which causes serious permanent disfigurement,
or which causes a permanent or protracted loss or impairment of the
function of any bodily part or organ.
Ohio has a two-way distinction where
"Physical harm to persons" means any injury, illness, or other
physiological impairment, regardless of its gravity or duration.
but
"Serious physical harm to persons" means any of the following:
(a) Any mental illness or condition of such gravity as would normally
require hospitalization or prolonged psychiatric treatment;
(b) Any physical harm that carries a substantial risk of death;
(c) Any physical harm that involves some permanent incapacity, whether
partial or total, or that involves some temporary, substantial
incapacity;
(d) Any physical harm that involves some permanent disfigurement or
that involves some temporary, serious disfigurement;
(e) Any physical harm that involves acute pain of such duration as to
result in substantial suffering or that involves any degree of
prolonged or intractable pain.
Texas has a rather different classification in terms of harm vs. serious bodily injury, the latter being
bodily injury that creates a substantial risk of death or that causes
death, serious permanent disfigurement, or protracted loss or
impairment of the function of any bodily member or organ.
but harm is
anything reasonably regarded as loss, disadvantage, or injury,
including harm to another person in whose welfare the person affected
is interested
thus can include financial losses and no physical contact.
The line in Florida is not bright.
