Jury Instructions on Serious Bodily Injury

In State v. Williams, 150 N.C. App. 497, 563 S.E.2d 616 (2002), the Court addressed the sufficiency of evidence of serious bodily injury where the jury instruction limited the definition of serious bodily injury to "'an injury that creates or causes a permanent or protracted condition that causes extreme pain.'" Id. at 503, 563 S.E.2d at 620. In Williams, the State presented evidence that the victim suffered a broken jaw that was wired shut for two months, and suffered back spasms for eight months, which resulted in two visits to the emergency room because of difficulty breathing. Id. In addition, the treating physician testified that the victim's injury was the type of injury that caused "'quite a bit' of pain and discomfort." Id. at 503-04, 563 S.E.2d at 620. Based on this evidence, our Court held that "a reasonable juror could find this evidence sufficient to conclude that the victim's injuries created a 'protracted condition that caused extreme pain.'" Id. at 504, 563 S.E.2d at 620.