In In re Michael P. (1996) 50 Cal.App.4th 1525, while being transported to a youth facility, a juvenile ward of the court repeatedly kicked the steering wheel and the driver of the van, causing the van to swerve back and forth across the road, nearly causing a head-on accident. The Court concluded: "In this case it was the threat of death and serious injury appellant created by almost causing a head-on automobile accident on the highway which makes his conduct most reprehensible. No criminal charge was alleged for that aspect of appellant's misconduct. Officer Paez testified he suffered 'soreness' from the kicking and no bruising. Paez did not further describe how hard he was kicked or his injury so as to support a finding the soreness was the sort of injury requiring professional medical treatment. The battery statute in question measures culpability by the seriousness of the inflicted injury. Hence, the witness's failure to further describe his injuries is fatal to respondent's position the evidence was indeed sufficient to support the juvenile court's finding of battery with injury on a peace officer." (In re Michael P., supra, 50 Cal.App.4th 1525, 1529.)