Maryland Code

Md. Code Ann., Crim. Law § 3-202 (2026)

§ 3-202

✓ current as of May 2026
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§3–202.

    (a)    In this section, “strangling” means impeding the normal breathing or blood circulation of another person by applying pressure to the other person’s throat or neck.

    (b)    (1)    A person may not intentionally cause or attempt to cause serious physical injury to another.

        (2)    A person may not commit an assault with a firearm, including:

            (i)    a handgun, antique firearm, rifle, shotgun, short–barreled shotgun, or short–barreled rifle, as those terms are defined in § 4–201 of this article;

            (ii)    an assault pistol, as defined in § 4–301 of this article;

            (iii)    a machine gun, as defined in § 4–401 of this article; and

            (iv)    a regulated firearm, as defined in § 5–101 of the Public Safety Article.

        (3)    A person may not commit an assault by intentionally strangling another.

    (c)    A person who violates this section is guilty of the felony of assault in the first degree and on conviction is subject to imprisonment not exceeding 25 years.


Notes of Decisions
Cited in 49 cases (13 in the last 5 years), 2004–2026 · leading case: Christian v. State, 951 A.2d 832 (Md. 2008).
Christian v. State, 951 A.2d 832 (Md. 2008). · cites it 8× “" Section 12A-1, the predecessor to current § 3-202 of the Criminal Law Article, provided as follows: "§ 12A-1.”
Curtin v. State, 903 A.2d 922 (Md. 2006). · cites it 4× “Curtin was subsequently arrested and charged with three counts of robbery with a deadly weapon in violation of Section 3-403 of the Criminal Law Article, [2] three counts of robbery in violation of Section 3-402 of the Criminal Law Article, [3] six counts of first degree assault…”
Smith v. State, 985 A.2d 1204 (Md. 2009). · cites it 4× “" § 4-204(a) of the Criminal Law Article. Use of a handgun in the commission of a felony is a misdemeanor.”
Harrison v. State, 855 A.2d 1220 (Md. 2004). · cites it 2× “This provision currently is codified under Maryland Code, § 3-202 of the Criminal Law Article (2002, 2003 Supp.”
Roary v. State, 867 A.2d 1095 (Md. 2005). · cites it 2× “Code (2002) § 3-202(a)(2) of the Criminal Law Article.”
Kelly v. State, 898 A.2d 419 (Md. 2006). · cites it 2× “Code (2002), § 3-202 of the Criminal Law Article. [4] Maryland Code (1957, 1996 Repl.”
Thornton v. State, 919 A.2d 678 (Md. 2007). · cites it 2× “Code (2002), § 3-202 of the Criminal Law Article, if he “intentionally cause[s] or at *730 tempt[s] to cause serious physical injury to another,” where “serious physical injury” means injury which, “[cjreates a substantial risk of death.”
United States v. Scott, 990 F.3d 94 (2d Cir. 2021). “17-A, § 208; Md. Code Ann., Crim. Law § 3-202 ; Minn. Stat.”
Gilmer v. State, 887 A.2d 549 (Md. 2005). · cites it 2× “Section 12A-1 has been recodified without substantive change as Maryland Code (2002), Section 3-202 of the Criminal Law Article.”
Smith v. State, 880 A.2d 288 (Md. 2005). · cites it 2× “Code (2002), § 3-202 of the Criminal Law Article. Md.Code (1957, 1996 Repl.”
United States v. Leland Schneider, 905 F.3d 1088 (8th Cir. 2018). “010 (1)(b) ; Md. Code Ann., Crim. Law § 3-202 (a)(1) ; Mich.”
Brye v. State, 980 A.2d 435 (Md. 2009). · cites it 2× “[11] Section 3-202 of the Criminal Law Article provides that "[a] person who violates this section is guilty of the felony of assault in the first degree and on conviction is subject to imprisonment not exceeding 25 years.”
— Md. Code Ann., Crim. Law § 3-202(a) — 2 cases
United States v. Marlon Haight, 892 F.3d 1271 (D.C. Cir. 2018).
Moody v. State, 59 A.3d 1047 (Md. Ct. Spec. App. 2013).
— Md. Code Ann., Crim. Law § 3-202(a)(1) — 1 case
Christian v. State, 951 A.2d 832 (Md. 2008). “" Section 12A-1, the predecessor to current § 3-202 of the Criminal Law Article, provided as follows: "§ 12A-1.”
— Md. Code Ann., Crim. Law § 3-202(a)(2) — 3 cases
Smith v. State, 985 A.2d 1204 (Md. 2009). “" § 4-204(a) of the Criminal Law Article. Use of a handgun in the commission of a felony is a misdemeanor.”
Roary v. State, 867 A.2d 1095 (Md. 2005). “Code (2002) § 3-202(a)(2) of the Criminal Law Article.”
Evans v. State, 23 A.3d 223 (Md. 2011).
— Md. Code Ann., Crim. Law § 3-202(a)(l) — 6 cases
Roary v. State, 867 A.2d 1095 (Md. 2005). “Code (2002) § 3-202(a)(2) of the Criminal Law Article.”
Christian v. State, 951 A.2d 832 (Md. 2008). “" Section 12A-1, the predecessor to current § 3-202 of the Criminal Law Article, provided as follows: "§ 12A-1.”
Teixeira v. State, 75 A.3d 371 (Md. Ct. Spec. App. 2013).
Chilcoat v. State, 843 A.2d 240 (Md. Ct. Spec. App. 2004).
Jones v. State, 114 A.3d 256 (Md. Ct. Spec. App. 2015).
— Md. Code Ann., Crim. Law § 3-202(b) — 3 cases
Smith v. State, 985 A.2d 1204 (Md. 2009). “" § 4-204(a) of the Criminal Law Article. Use of a handgun in the commission of a felony is a misdemeanor.”
McCullough v. State, 168 A.3d 1045 (Md. Ct. Spec. App. 2017).
Brown v. State, 901 A.2d 846 (Md. Ct. Spec. App. 2006).
— Md. Code Ann., Crim. Law § 3-202(b)(1) — 1 case
— Md. Code Ann., Crim. Law § 3-202(b)(3) — 1 case
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