Summary
The Delaware Supreme Court affirmed Valerie Cauffman's convictions for third-degree assault and felony resisting arrest. The Court held that the evidence did not provide a rational basis for a misdemeanor resisting-arrest instruction because the felony provision did not require proof that Cauffman specifically intended to injure the officer.
Topics
Practice areas
Questions Presented
- Whether the Superior Court erred by refusing to instruct the jury on misdemeanor resisting arrest as a lesser included offense of felony resisting arrest.
- Whether 11 Del. C. § 1257(a)(3) requires proof that the defendant specifically intended to injure the peace officer.
- Whether there was a rational evidentiary basis for acquitting Cauffman of felony resisting arrest while convicting her of misdemeanor resisting arrest.
Holdings
- Section 1257(a)(3) does not require proof that the defendant specifically intended to cause injury to the peace officer; the provision applies when the defendant injures or struggles with the peace officer causing injury.
- The trial court properly refused to give the misdemeanor resisting arrest instruction because the evidence did not provide a rational basis for acquitting Cauffman of felony resisting arrest while convicting her of misdemeanor resisting arrest.
Key quotations
“The trial court must instruct the jury “only if ‘there is a rational basis in the evidence for a verdict acquitting the defendant of the offense charged and convicting him of the included offense[s].’”” (5)
“Here, Cauffman acknowledged that she struggled with the police officer and that the police officer was injured.” (8)
“Accordingly, because 11 Del. C. § 1257(a)(3) did not require proof that Cauffman intended to injure a peace officer, there was no reasonable basis for the jury to convict her of the lesser included offense of misdemeanor Resisting Arrest, rather than felony Resisting Arrest.” (8)
Factual background
Cauffman called police to report that her intoxicated fiancé was acting erratically in their home. When officers attempted to enter after taking the fiancé into custody, Cauffman ran toward the door, slammed it into an officer's arm and foot, and resisted the officer's efforts to detain her. The officer suffered an arm injury requiring ten sutures and difficulty walking for several days, and Cauffman acknowledged that she struggled with the officer.
Procedural history
Cauffman was indicted in the Superior Court for assault in the second degree and felony resisting arrest. After the State's case, she requested a lesser included offense instruction for misdemeanor resisting arrest, which the trial court denied. The jury convicted her of the lesser included offense of assault in the third degree and felony resisting arrest. The Delaware Supreme Court affirmed.