Does the victim have to have a visible physical injury for the defendant to be convicted of domestic violence or spousal abuse?

No, and many times, there’s not going to be an outward manifestation of an injury. There’s not gonna be bruising. There’s not gonna be cuts. In fact, I’ve handled a case or two where there were people who knew how to inflict injuries and not leave bruises and not leave cuts and scars.

The answer is absolutely not. All it takes is a credible witness to identify and to testify against the perpetrator to bring them to justice and a willing prosecutor.