offense for burglary. However, because Connecticut law provides that burglary may be predicated on any crime, see Conn. Gen. Stat. § 58a-108 (2012), that decision does not aid our analysis. 123 Like Colorado, Washington limits qualifying predicate offenses for burglary to "crime[s] against a person or property." Wash. Rev.Code §§ 9A.52.020(1), 9A.52.025(1), 9A.52.030(1). Unlike Colorado, however, a Washington statute expressly defines "crimes against persons" and "crimes against property." Wash. Rev.Code § 9.94A.411(2)(a). Obstructing a law enforcement officer does not appear in either category. For this reason, obstructing a law enforcement officer is not a valid predicate offense for burglary under Washington law. See State v. Devitt, 152 Wash.App. 907, 218 P.3d 647, 648-49 (2009) (<HOLDING>). 124 Those states that do not statutorily
holding that a question about present employment in field of law enforcement did not trigger disclosure of past employment in field of law enforcement holding omission in the jury instruction of element of offense requires a new trial holding attempted aggravated assault on a law enforcement officer is not a crime in florida holding in addition that offense of obstructing a law enforcement officer did not meet therein element of burglary holding that the trial court committed fundamental error in not instructing the jury on the knowledge element of the offense of resisting an officer without violence when that element was in dispute at trial