Ricks v. CommonwealthAnnotate this Case
Talmage Ricks was convicted of strangulation resulting in bodily injury in violation of Va. Code 18.2-51.6. In a separate criminal case, Edward Chilton was also convicted of strangulation resulting in bodily injury. Both defendants appealed, arguing that the evidence was insufficient to support their convictions. The Court of Appeals denied Ricks’ petition for appeal but reversed Chilton’s conviction and dismissed the indictment against him. The Supreme Court considered the two appeals together because they presented similar assignments of error regarding the wounding or bodily injury element necessary to prove the crime of strangulation in violation of section 18.2-51.6. The Supreme Court affirmed in both cases, holding that the Court of Appeals did not err in its findings regarding the sufficiency of the evidence to prove bodily injury.