Yes, Bart has been strangled by Homer. Bart has also been strangled by Lisa, strangled by Dr. Zander, strangled by three Secret Service agents simultaneously, slapped in the face by Miss Krabappel, and spanked by the first former President Bush. So it makes sense that Batman would strangle Bart Simpson. From the late 1990s to 2019, Bart Simpson was an evil sociopathic monster who caused trouble without hesitation, without restraint, without mercy, without remorse, and worst of all-without cause. He caused trouble just for the sake of causing trouble, making him the ten year-old equivalent of Heath Ledger's Joker from The Dark Knight. Spend enough time with that Bart Simpson, and he's sure to bring out the worst in you.
Because of this, everyone in Springfield (with the possible exception of his family) hates Bart Simpson. That's why Homer strangled Bart on live television without getting arrested. That's why Police Chief Clancy Wiggum got to keep his job after telling Bart to jump off a water tower in "Boys Of Bummer".
Only when Disney took over FOX in 2019 did things change. Homer stopped strangling Bart, and Bart's behavior was much better.