Va. Code » Title 18.2. Crimes and Offenses Generally » Chapter 4. Crimes Against the Person » Article 4. Assaults and Bodily Woundings
Virginia Code

Va. Code Ann. § 18.2-51.6 (2026)

Strangulation or suffocation of another; penalty

✓ current as of May 2026
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A. Any person who, without consent, impedes the blood circulation or respiration of another person by knowingly, intentionally, and unlawfully applying pressure to the neck of such person resulting in the wounding or bodily injury of such person is guilty of strangulation, a Class 6 felony.

B. Any person who, without consent, impedes the blood circulation or respiration of another person by knowingly, intentionally, and unlawfully blocking or obstructing the airway of such person resulting in the wounding or bodily injury of such person is guilty of suffocation, a Class 6 felony.

2012, cc. 577, 602; 2023, cc. 709, 710.

Notes of Decisions
Cited in 63 cases (48 in the last 5 years), 2014–2026 · leading case: Eric William Wandemberg v. Commonwealth of Virginia, 825 S.E.2d 291 (Va. Ct. App. 2019).
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Eric William Wandemberg v. Commonwealth of Virginia, 825 S.E.2d 291 (Va. Ct. App. 2019). · cites it 20× “Following a bench trial, the Circuit Court of Chesterfield County (the “circuit court”) convicted Eric William Wandemberg (“Wandemberg”) of two counts of strangulation, in violation of Code § 18.2-51.6, two counts of misdemeanor assault and battery, in violation of Code § 18.”
Ricks v. Commonwealth, 778 S.E.2d 332 (Va. 2015). · cites it 18× “We consider these two appeals together because they present similar assignments of error regarding the wounding or bodily injury element necessary to prove the crime of strangulation in violation of Code § 18.2-51.6. In each case, we consider whether the Court of Appeals erred…”
Robert Wayne Dawson, II v. Commonwealth of Virginia, 758 S.E.2d 94 (Va. Ct. App. 2014). · cites it 9× “CR12-238 (violation of Va. Code § 18.2-51.6) by ruling “I do believe the evidence supports that charge,” because the Commonwealth’s evidence was insufficient as a matter of law to prove that any strangulation caused a wounding or bodily injury to Pittman, the victim.”
Lewis v. Commonwealth, 813 S.E.2d 732 (Va. 2018). “2-52, (v) strangulation in violation of § 18.2-51.6, or (vi) an offense under the law of any other jurisdiction which has the same elements of any of the above offenses, in any combination, all of which occurred within a period of 20 years, and each of which occurred on a…”
Kevin Cody v. Commonwealth of Virginia, 812 S.E.2d 466 (Va. Ct. App. 2018). · cites it 4× “Appellant Kevin Cody (“Cody”) was convicted on February 16, 2017, in the Circuit Court of Loudoun County (the “circuit court”) for strangulation of another to cause wounding or injury, in violation of Code § 18.2-51.6, assault and battery of a family member, in violation of Code…”
Commonwealth v. Baust, 89 Va. Cir. 267 (Virginia Beach Cir. Ct. 2014). · cites it 2× “David Charles Baust is charged by indictment with violating Code of Virginia § 18.2-51.6, Strangling Another Causing Wounding or Injury.”
Christopher Parris Cabral v. Commonwealth of Virginia, 815 S.E.2d 805 (Va. Ct. App. 2018). · cites it 2× “2-58 and -26; strangulation, in violation of Code § 18.2-51.6; abduction with intent to defile, in violation of Code § 18.”
United States v. Autrey, 263 F. Supp. 3d 582 (E.D. Va. 2017). “Indeed, even if a defendant lacks “malice,” that defendant violates the Virginia maiming statute only if he causes bodily injury with "intent to maim, disfigure, disable, or kill.”
Andrew Gordon Luck v. Commonwealth of Virginia (Va. Ct. App. 2024). · cites it 10× “7 Code § 18.2-51.6 was amended in 2023 to add the separate offense of suffocation as “blocking or obstructing the airway.”
Tony Lee Saunders v. Commonwealth of Virginia (Va. Ct. App. 2024). · cites it 9× “Strangulation under Code § 18.2-51.6 is defined as “without consent, imped[ing] the blood circulation or respiration of another person by knowingly, intentionally, and unlawfully” either “applying pressure to the neck” or “blocking or obstructing the airway” causing “wounding or…”
Edward Chilton, s/k/a Edward Corndell Chilton v. Commonwealth of Virginia (Va. Ct. App. 2014). · cites it 14× “Edward Corndell Chilton was convicted of strangulation pursuant to Code § 18.2-51.6. On appeal, Chilton argues that the trial court erred in finding that the victim suffered a bodily injury as a result of the application of pressure to her neck.”
Jeremy Wayne Dodge v. Commonwealth of Virginia (Va. Ct. App. 2022). · cites it 8× “” Code § 18.2-51.6 provides that “[a]ny person who, without consent, impedes the blood circulation or respiration of another person by knowingly, intentionally, and unlawfully applying pressure to the neck of such person resulting in the wounding or bodily injury of such person…”
Show all 63 citing cases →
— Va. Code Ann. § 18.2-51.6(A) — 5 cases
Michael Thomas Dalton v. Commonwealth of Virginia (Va. Ct. App. 2024).
Andrew Gordon Luck v. Commonwealth of Virginia (Va. Ct. App. 2024). “7 Code § 18.2-51.6 was amended in 2023 to add the separate offense of suffocation as “blocking or obstructing the airway.”
Adam Ross Cunningham, a/k/a Swag Cunningham v. Commonwealth of Virginia (Va. Ct. App. 2026).
Ruanta Deangelao Price v. Commonwealth of Virginia (Va. Ct. App. 2023).
Andrew Luke Neff v. Commonwealth of Virginia (Va. Ct. App. 2024).
— Va. Code Ann. § 18.2-51.6(B) — 1 case
Andrew Gordon Luck v. Commonwealth of Virginia (Va. Ct. App. 2024). “7 Code § 18.2-51.6 was amended in 2023 to add the separate offense of suffocation as “blocking or obstructing the airway.”
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