O.R. v. State

O.R. appeals an adjudication of delinquency for battery on a law enforcement officer and resisting an officer without violence. During his bench trial, O.R. argued that the complaining police officer used excessive force in detaining him, thereby excusing O.R.’s conduct as self-defense. During cross-examination of the complaining officer, O.R. was precluded from cross-examining the officer about other acts of misconduct. Moreover, the trial court refused to allow O.R. to proffer the testimony he intended to elicit.

We conclude that the trial court erred by denying the proffer. Jackson v.…