State v. Bohannon, ___ N.C. App. ___, 786 S.E.2d 781 (Jun. 7, 2016)

Because subarachnoid hemorrhaging constitutes “serious bodily injury,” the evidence was sufficient to convict the defendant of felonious child-abuse inflicting serious bodily injury under G.S. 14-318.4(a3). The court rejected the defendant’s argument that since the child did not actually suffer acute consequences from the hemorrhages, his brain injury never presented a substantial risk of death. Among other things, a medical expert testified that bleeding on the brain could lead to a number of issues including developmental delays and even “acute illness and death.” Citing this and other evidence, the court concluded that there was sufficient evidence that the child’s brain injury created a substantial risk of death.