Ricks v. Commonwealth

Opinion by Justice CLEO E. POWELL.

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 in its findings regarding the sufficiency of the evidence to prove bodily injury.

I. BACKGROUND

A. Ricks

Talmage Donnell Ricks ("Ricks") was convicted by the Circuit Court of Southampton County ("Southampton Circuit Court") of strangulation resulting in bodily injury in violation of Code §…