Robert Wayne Dawson, II v. Commonwealth of Virginia, 758 S.E.2d 94

Dawson was convicted of strangulation under Va. Code § 18.2-51.6 after a bench trial in Lancaster County.
The Commonwealth challenged the sufficiency of evidence showing that strangulation caused Pittman’s wounding or bodily injury.
In July 2012 Dawson and Pittman, his mother, were homeless and staying with Pittman in Lancaster County after leaving a Richmond hotel.
Dawson assaulted Pittman on a back deck, grabbing her arms and pinning her neck, while she held their child nearby.
Pittman testified that Dawson pressed on her neck, limited her breathing, and caused her to feel like she was drowning; bruises appeared later around the neck.
Medical records showed a rib fracture and post-concussive symptoms; Pittman required hospital care but had no lasting neck injuries noted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether strangulation caused bodily injury	Dawson argues no bodily injury causally resulted from neck pressure.	Commonwealth contends neck pressure impeded respiration and caused bodily injury.	Affirmed; bodily injury shown by neck compression and bruising evidence.

Luck v. Commonwealth, 32 Va. App. 827, 531 S.E.2d 41 (2000) (bodily injury includes any bodily hurt; ordinary meaning applied)
Johnson v. Commonwealth, 184 Va. 409, 35 S.E.2d 594 (1945) (bodily injury includes injuries beyond skin breaks)
Campbell v. Commonwealth, 12 Va. App. 476, 405 S.E.2d 1 (1991) (broad interpretation of bodily injury includes non-skin injuries)
English v. Commonwealth, 58 Va. App. 711, 715 S.E.2d 391 (2011) (reiterates everyday meaning of bodily injury)
Stein v. Commonwealth, 12 Va. App. 65, 402 S.E.2d 238 (1991) (statutory interpretation guiding bodily injury standard)