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Abstract: 

A case from Washington State sought to resolve the question of whether multiple crimes, including rape, strangulation, and attempted homicide, were the “same criminal conduct” or discrete offenses for sentencing purposes. In State v. House, 553 P.3d 1157, (Wash. Ct. App. 2024), the state’s supreme court ruled that the sentencing committed no error in handing down multiple sentences for each discrete act committed during a domestic violence home invasion and attack. In Ohio, evidence of substantial risk of serious harm was sufficient to support strangulation convictions, even though the victim recanted. State v. Osborne, 2024 WL 2861759 (Ohio Ct. App. 2024). In Illinois, the state’s highest appellate court approved pretrial detention of defendant charged with aggravated domestic battery by strangulation. People v. Andino-Acosta, 2024 Il. App. 2d 230463.

Keywords: Strangulation; Sentencing; Recantation

Affiliations:  1: Contributing Editor; 2: Associate Editor.