People v. Richards

In People v. Richards (128 AD2d 387 [1st Dept 1987], lv denied 70 NY2d 654 [1987]), the Court held that "no particular degree of impairment of physical condition or substantial pain . . . is required to prove physical injury". In that case, grand jury evidence that the attempted rape victim had her head slammed into the sides of an elevator causing "pain and subsequent swelling" was held legally sufficient (id. at 387).