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Maryland (2007/2020)

Hounshell v. State, (1985) 61 Md.App. 364

Not necessary to show that a required amount of time be presented to establish premeditation. Strangulation does not take place immediately but rather spans continuous period of time or series of continuous acts of choking until death occurs. The defendant argued that that death happened almost immediately and that he didn’t have time to premeditate her death.

Hammond v. Maryland, (2016) 2016 WL 3783509 Unpublished

Substantial bodily injury was found where the victim was seriously beaten and strangled.

Wright v. State (2017) 2017 WL 4117886 Unpublished

The victim was sexually assaulted and strangled. There was substantial bodily injury where strangulation was forceful; the victim thought she was going to die. She was afraid to report. There was a subsequent threat to kill.

 Cooper v. Rodriquez (2015) 443 Md.App 680

There was gross negligence by a guard for not stopping a strangulation; no immunity.