State of Washington v. Rodriguez: Examining the Strangulation Prong of the Assault 2 Statute
In 2007 the Washington Legislature added another prong to the Assault Second Degree statute, defining “assault by strangulation or suffocation” as its own means of committing Assault 2, a “strike” offense under Washington law. Previously, an incident of strangulation would have to produce “substantial bodily harm” in order to meet the definition of Assault 2, but that is no longer the case. Instead, the…