DC Officer’s Conviction Upheld for Using Forbidden Neck Holds

Oct. 10, 2025, 6:05 PM UTC

A Washington police officer’s conviction for violating two citizens’ rights by using unauthorized neck restraints on them in separate fast-food restaurant incidents was valid, the DC Circuit said Friday.

Officer Mark L. Clark’s arguments that a jury instruction improperly explained the willfulness element of the crime he was charged with and that there was insufficient evidence that he knew he was violating the victims’ rights were rejected by the US Court of Appeals for the District of Columbia Circuit.

Clark was accused of using a trachea hold on Daquan Toland during an altercation at a McDonald’s. Five days later, he ...

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