"Whether the victim's injuries rise to the level of great bodily harm is a question for the trier of fact." People v. Cisneros , 2013 IL App (3d) 110851, ¶ 12, 374 Ill.Dec. 716, 996 N.E.2d 163. ¶ 18 We find that the evidence in this case, when viewed in the light most favorable to the State, was sufficient for a rational trier of fact to find that the State had proven beyond a reasonable doubt that Lofdahl suffered great bodily harm as a result of the battery.

¶ 18 The photographs from the scene were presented to the court and document Hamende's injuries caused significant bleeding, as evidenced by the blood smeared on the desk and the droplets of blood on the floor. See People v. Cisneros, 2013 IL App (3d) 110851 ¶ 13 (finding great bodily harm where victim's shirt was "completely soaked" with blood). ¶ 19 Hamende testified that the injury to his ear required 17 stitches.

Whether an injury rises to the level of great bodily harm is a question for the trier of fact. People v. Cisneros, 2013 IL App (3d) 110851, ¶ 12. In making that determination, "the relevant question for the trier of fact to answer is not what the victim did or did not do to treat the injury but what injuries the victim in fact received."

Instead, it is the role of the jury as the trier of fact to determine whether the injuries that the victim sustained rose to the level of great bodily harm. People v. Cisneros, 2013 IL App (3d) 110851, ¶ 12. The trier of fact is entitled to consider the description of the attack, the victim's injuries, and the amount of blood caused by those injuries.

Rather than finding that lacerations, bruises or abrasions are strictly considered mere "bodily harm," this court has consistently found that the trier of fact makes the determination of what constitutes "great bodily harm" based on the injuries the victim actually received (People v. Psichalinos, 229 Ill. App. 3d 1058, 1068 (1992)) and can be a matter of degree of harm from these and other injuries. See People v. Cisneros, 2013 IL App (3d) 110851, ¶ 13; People v. Matthews, 126 Ill. App. 3d 710, 715 (1984). Moreover, hospitalization of the victim and permanent disability or disfigurement are not required.

¶ 35 Defendant's blanket assertion that bruises and abrasions cannot constitute great bodily harm is without merit. See People v. Cisneros, 2013 IL App (3d) 110851, ¶¶ 18-20 (noting that the supreme court's discussion of battery in Mays was not useful in distinguishing simple battery from aggravated battery because the Mays court did not discuss aggravated battery); see also People v. Thompson, 2021 IL App (1st) 182371-U, ¶ 30 (agreeing with Cisneros that "while minor lacerations such as a small cut to a finger caused by a kitchen knife do not rise to the level of great bodily harm, other lacerations may rise to such a level if sufficient evidence is presented as to their severity"). Under Illinois Supreme Court Rule 23(e)(1) (eff. Feb. 1, 2021), unpublished orders entered on or after January 1, 2021, may be cited for persuasive purposes.

This is not to say, however, that lacerations cannot amount to great bodily harm. See People v. Cisneros, 2013 IL App (3d) 110851, ¶¶ 16, 18. Rather, "to constitute great bodily harm, lacerations would have to be of a grave and serious character, as opposed to of a minor or trivial character." Id. ¶ 27 (McDade, J., specially concurring).

great bodily harm is a question for the trier of fact. People v. Cisneros, 2013 IL App (3d) 110851, ¶ 12. In making that determination, "the relevant question for the trier of fact to answer is not what the victim did or did not do to treat the injury but what injuries the victim in fact received."

It appears to us that the court's statement in Mays was intended not to set a baseline for proving simple battery or to distinguish "bodily harm" from "great bodily harm," but only to differentiate between battery based on bodily harm and battery based on insulting or provoking contact. See People v. Cisneros , 2013 IL App (3d) 110851, ¶¶ 16–18, 374 Ill.Dec. 716, 996 N.E.2d 163 ; see also Mays , 91 Ill. 2d at 256, 62 Ill.Dec. 945, 437 N.E.2d 633. Thus, beyond reflecting a commonsense understanding of "bodily harm," whether "great" or not so great, Mays does not bear on the construction of "great bodily harm."

¶ 27 Olidge's testimony, corroborated by Baskin and the photographs, was sufficient to establish the seriousness of her injuries. See, e.g., People v. Doran, 256 Ill. App. 3d 131, 136 (1993) (finding sufficient evidence to support great bodily harm where the record contained pictures to demonstrate the victim's injuries, which included bruises, lacerations, and a concussion, and the victim showed the scar on his forehead); see also People v. Cisneros, 2013 IL App (3d) 110851, ¶ 20 ("photographic evidence and a visual display" of scars was sufficient evidence to show great bodily harm). The absence of medical testimony regarding the severity or permanency of the victim's lacerations did not preclude the factfinder from finding great bodily harm. Cisneros,