350 Conn. 19
Conn.2024Background
- Defendant Raikes Y. Delacruz-Gomez was convicted after a jury trial of assaulting public safety personnel and interfering with an officer in Waterbury, Connecticut.
- The convictions stemmed from an incident where officers executing an arrest warrant for the defendant (and his son) forcibly entered his residence, during which the defendant injured a police officer.
- At trial, the State introduced evidence specifying the felony charges (assault in the first degree and criminal possession of a firearm) listed in the defendant’s outstanding warrant and identified the law enforcement team as the "Violent Fugitive Task Force."
- The defendant objected to the admission of the specific charge names and the task force designation, arguing they were unduly prejudicial.
- The trial court admitted the evidence, the Appellate Court affirmed the conviction, and on certification the defendant appealed to the Connecticut Supreme Court.
- The Supreme Court affirmed the conviction, holding some evidence should have been excluded but that any error was harmless.
Issues
| Issue | Defendant's Argument | State's Argument | Held |
|---|---|---|---|
| Admission of warrant charge names | Unduly prejudicial; portrays him as violent/dangerous | Necessary to show officers’ conduct/reasonableness | Properly admitted; probative value outweighed prejudice |
| Admission of "Violent Fugitive Task Force" name | Prejudicial; labels defendant as a violent fugitive | Explains officers’ presence/use of force | Should not have been admitted; no probative value; harmless error |
Key Cases Cited
- State v. Raynor, 175 Conn. App. 409 (2017) (discusses balancing probative value and prejudice in admitting evidence)
- State v. Davis, 261 Conn. 553 (2002) (clarifies defense to assault/interfering with officer is lack of duty performance)
- State v. Graham, 200 Conn. 9 (1986) (heightened prejudice when prior crime is similar to charged offense)
- State v. Collins, 299 Conn. 567 (2011) (general rule against admitting prior misconduct evidence to show propensity)
- State v. Nixon, 32 Conn. App. 224 (1993) (elements of assault of a peace officer under Connecticut law)