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Connecticut (2007)

State v. Lewis (2019)

Officer had reasonable and articulable suspicion to suspect the defendant might have armed dangerous because he was a suspect in an act of domestic violence that involved choking. Because a domestic violence incident involving choking increases the probability that the suspect might be armed with a weapon, be it a gun or other kind of weapon, it also creates reasonable suspicion that the suspect might threaten the safety of the officer. Studies show that there is a strong link between domestic violence cases in which the suspect is armed and officers are killed or shot in the line of duty.


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State v. Linder (2017, CT) 172 Conn.App. 231

The defendant claimed insufficiency of evidence because there was no physical injury. The defendant wrapped his hands around the victim’s neck and squeezed for approximately 20 seconds. The victim called 911.

The victim had a hoarse voice, difficulty swallowing, bruising to front of neck, and tenderness, which expert testified was consistent with strangulation

The defendant claimed that, because the victim didn’t have other symptoms of strangulation, such as bruising on the back of her neck, petechiae hemorrhaging in her eyes, swelling around her vocal cords, or fractures, that he did not harm the victim in a manner consistent with strangulation, and there was no evidence that the victim couldn’t breathe

Based on the symptoms, the court held that the victim did report, and the medical testimony that those signs and symptoms were consistent with strangulation is was reasonable to infer that the victim had difficulty breathing.

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