NC General Statutes

N.C. Gen. Stat. § 14-32.4 (2026)

Assault inflicting serious bodily injury; strangulation; penalties

✓ current as of July 2026

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(a) Unless the conduct is covered under some other provision of law providing greater punishment, any person who assaults another person and inflicts serious bodily injury is guilty of a Class F felony. "Serious bodily injury" is defined as bodily injury that creates a substantial risk of death, or that causes serious permanent disfigurement, coma, a permanent or protracted condition that causes extreme pain, or permanent or protracted loss or impairment of the function of any bodily member or organ, or that results in prolonged hospitalization.

(b) Unless the conduct is covered under some other provision of law providing greater punishment, any person who assaults another person and inflicts physical injury by strangulation is guilty of a Class H felony. (1996, 2nd Ex. Sess., c. 18, s. 20.13(a); 2004-186, s. 9.1.)

Notes of Decisions

Cited in 84 cases (19 in the last 5 years), 1998–2026 · leading case: State v. Williams, 689 S.E.2d 412 (N.C. Ct. App. 2009).

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State v. Williams, 689 S.E.2d 412 (N.C. Ct. App. 2009). · cites it 46× “See N.C. Gen. Stat. § 14-32.4 (a) (2007). Under this statute, serious bodily injury is defined as “bodily injury that creates a substantial risk of death, or that causes serious permanent disfigurement, coma, a permanent or protracted condition that causes extreme pain, or…”

State v. Williams, 563 S.E.2d 616 (N.C. Ct. App. 2002). · cites it 37× “Defendant was indicted for assault inflicting serious bodily injury in violation of N.C. Gen. Stat. § 14-32.4 , felonious breaking or entering, first degree trespass, and resisting a public officer.”

State v. Ezell, 582 S.E.2d 679 (N.C. Ct. App. 2003). · cites it 25× “Here, N.C. Gen. Stat. § 14-32.4 contains specific language indicating that the legislature intended that § 14-32.”

State v. Hannah, 563 S.E.2d 1 (N.C. Ct. App. 2002). · cites it 21× “§ 14-51, and assault inflicting serious bodily injury, in violation of N.C.G.S. § 14-32.4. For the reasons herein, we hold no error as to defendant’s conviction for first-degree burglary; however, we vacate his assault conviction and order a new trial.”

State v. McCoy, 620 S.E.2d 863 (N.C. Ct. App. 2005). · cites it 13× “§ 14-32 ) for offenses on 6 November 2002, and assault inflicting serious injury and assault with a deadly weapon inflicting serious injury for offenses on 19 November 2002.”

State v. Lowe, 572 S.E.2d 850 (N.C. Ct. App. 2002). · cites it 17× “Defendant argues that under N.C. Gen. Stat. § 14-32.4 , there is insufficient evidence to find him guilty of “serious bodily injury,” as defined by that statute.”

State v. Jamison, 758 S.E.2d 666 (N.C. Ct. App. 2014). · cites it 11× “” N.C. Gen. Stat. § 14-32.4 (2013). In interpreting this statutory language, we have previously held that “the General Assembly intended for N.”

State v. Crawford, 606 S.E.2d 375 (N.C. Ct. App. 2005). · cites it 13× “North Carolina statutory law defines “serious bodily injury” as “bodily injury that creates a substantial risk of death, or that causes serious permanent disfigurement, coma, a permanent or protracted condition that causes extreme pain, or permanent or protracted loss or…”

State v. Floyd, 794 S.E.2d 460 (N.C. 2016). · cites it 6× “, N.C.G.S. § 14-32.4(a) (2015), “[t]here 2 Although the 1912 decision in Hewett stated that “[t]here is no such criminal offense as an ‘attempt to commit rape,’ ” the offense of attempted rape is recognized in our law today.”

State v. Brown, 628 S.E.2d 787 (N.C. Ct. App. 2006). · cites it 13× “4 , which provides in pertinent part: (a) Unless the conduct is covered under some other provision of law providing greater punishment, any person who assaults another person and inflicts serious bodily injury is guilty of a Class F felony. “Serious bodily injury” is defined as…”

State v. McPhaul, 808 S.E.2d 294 (N.C. Ct. App. 2017). · cites it 5× “N.C. Gen. Stat. § 14-32.4 (a). We have held that the inclusion of this prefatory clause indicates "that the legislature intended that § 14-32.”

State v. Braxton, 643 S.E.2d 637 (N.C. Ct. App. 2007). · cites it 12× “See N.C. Gen. Stat. § 14-32.4 (b) (2005). There is nothing in the statutory definition of assault by strangulation which requires proof that the perpetrator restrained the victim in any manner, with the exception of the act of strangulation.”

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— N.C. Gen. Stat. § 14-32.4(a) — 12 cases

State v. Williams, 689 S.E.2d 412 (N.C. Ct. App. 2009). “See N.C. Gen. Stat. § 14-32.4 (a) (2007). Under this statute, serious bodily injury is defined as “bodily injury that creates a substantial risk of death, or that causes serious permanent disfigurement, coma, a permanent or protracted condition that causes extreme pain, or…”

State v. Floyd, 794 S.E.2d 460 (N.C. 2016). “, N.C.G.S. § 14-32.4(a) (2015), “[t]here 2 Although the 1912 decision in Hewett stated that “[t]here is no such criminal offense as an ‘attempt to commit rape,’ ” the offense of attempted rape is recognized in our law today.”

State v. Brown, 628 S.E.2d 787 (N.C. Ct. App. 2006). “4 , which provides in pertinent part: (a) Unless the conduct is covered under some other provision of law providing greater punishment, any person who assaults another person and inflicts serious bodily injury is guilty of a Class F felony. “Serious bodily injury” is defined as…”

State v. Burwell, 808 S.E.2d 583 (N.C. Ct. App. 2017).

State v. Downs, 635 S.E.2d 518 (N.C. Ct. App. 2006).

— N.C. Gen. Stat. § 14-32.4(b) — 10 cases

State v. Braxton, 643 S.E.2d 637 (N.C. Ct. App. 2007). “See N.C. Gen. Stat. § 14-32.4 (b) (2005). There is nothing in the statutory definition of assault by strangulation which requires proof that the perpetrator restrained the victim in any manner, with the exception of the act of strangulation.”

State v. Tadlock (N.C. 2026).

State v. Prince (N.C. Ct. App. 2020).

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