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State v. Cais
Citations: 59 Conn. App. 186; 754 A.2d 858; 2000 Conn. App. LEXIS 367Docket: AC 19468
Court: Connecticut Appellate Court; August 1, 2000; Connecticut; State Appellate Court
Milan Cais appeals his conviction for interfering with a police officer under General Statutes § 53a-167a. The trial court found sufficient evidence to support the conviction, which Cais contests on grounds that he lacked the intent to interfere. On July 16, 1998, Trooper Michael Gignac had tagged an abandoned van in East Haddam. Constable Richard Patchell, at Gignac’s request, found the van with the tag partially removed and initiated towing procedures. During this time, Cais approached the van, and after a brief conversation with Patchell, he left but later returned to move the van while Patchell was still at the driver’s side window. As Patchell attempted to prevent Cais from driving away, Cais rolled up the window, pinning Patchell’s arm, and drove a short distance before Patchell used capstun to incapacitate him. Cais fled but was eventually apprehended after resisting arrest. Cais argued that his actions were involuntary due to the capstun and that the evidence did not support a conviction. The court employed a two-part standard for reviewing sufficiency of evidence, focusing on whether a reasonable trier of fact could find guilt beyond a reasonable doubt. The court rejected Cais's request to re-evaluate witness credibility, affirming that this is solely within the trier of fact’s discretion. The court concluded that evidence showed Cais was not merely acting involuntarily, noting his initial actions of rolling up the window and moving the van prior to the use of capstun. The court affirmed the conviction, establishing that Cais’s conduct met the statutory definition of interfering with an officer.