66, 653 S.E.2d 358 (2007). 550, 529 S.E.2d 381 (2000). Because the defendant ignored the officers' requests to provide identification, and instead engaged in a fight and wrestling match with the officers in an attempt to get to a brother's residence, while a search warrant was being executed, the evidence was sufficient to support the defendant's conviction for misdemeanor obstruction in violation of O.C.G.A. 139 (1913). 249, 635 S.E.2d 853 (2006). Defendant's motion for a directed verdict of acquittal was properly denied as the evidence was sufficient to convict the defendant of two misdemeanor counts of obstructing a law enforcement officer because there was ample testimony about the existence and purpose of the order pursuant to which they assisted the deputies in taking the defendant into custody for transport to a mental health facility; the defendant refused to comply with the officers' verbal commands, and began fighting with the officers when the officers tried to detain the defendant; the defendant hit, kicked, and scratched the officers; and the officers and the defendant fell to the ground, and the defendant continued fighting until the officers were able to gain control of the defendant. 860, 534 S.E.2d 544 (2000). A conviction for felony obstruction of a law enforcement officer may be punished by imprisonment of as little as one, or as much as five years. Mayfield v. State, 276 Ga. App. 650, 629 S.E.2d 438 (2006). 835, 652 S.E.2d 870 (2007). 835, 500 S.E.2d 14 (1998). Coroner Kenny Cooper: 'After all we've been through, we're still alive'. - Evidence that defendant gave police a fictitious name and social security number when police questioned defendant about a burglary was sufficient to sustain defendant's conviction of burglary and obstruction of a law enforcement officer. Additionally, it was not necessary to introduce the city ordinance on disorderly conduct in order to convict. 757, 754 S.E.2d 798 (2014). unruly, ungovernable, intractable, refractory, recalcitrant, willful, headstrong mean not submissive to government or control. 247, 630 S.E.2d 847 (2006). 799, 643 S.E.2d 262 (2007); Grant v. State, 289 Ga. App. Moreover, defendant's behavior was threatening enough to compel the officer to draw a weapon and to order defendant to lie on the floor, facts from which the court could have inferred the officer was in reasonable fear of injury and thus had probable cause to arrest defendant for disorderly conduct, despite the lack of testimony from the bar owner or the waitress. - U.S. Strobhert v. State, 241 Ga. App. 16-10-24 (a) describes the elements of misdemeanor obstruction of a When defendant gave false identifying information to officers after a traffic stop, the defendant provided the officers with probable cause for arrest; it followed that the evidence was sufficient to sustain the defendant's conviction. - Evidence that the handcuffed defendant kicked at the arresting officer and threatened to break the officer's leg was sufficient to convict defendant of felony obstruction, as the jury could have reasonably found that the threat of violence and attempts to kick the officer tended to hinder and impede the officer's efforts to secure defendant. 482, 600 S.E.2d 437 (2004). 16-10-24(a) since a reasonable officer could not have interpreted the conduct as a knowing and willful act of hindrance or obstruction or as a threat to officer safety. 156, 545 S.E.2d 312 (2001). Sign up for our free summaries and get the latest delivered directly to you. For article on the 2015 amendment of this Code section, see 32 Ga. St. U.L. 42, 479 S.E.2d 454 (1996); Nunn v. State, 224 Ga. App. - Trial court did not improperly increase the defendant's sentence because, although the trial court orally declared that the defendant would serve two concurrent 12-month sentences for the battery and obstruction convictions, and the defendant was taken into custody immediately, on the same day, before the defendant was taken into custody and began to serve the defendant's sentence, the trial court signed a written sentence stating that the defendant would serve two consecutive 12-month sentences for the two convictions. 219, 483 S.E.2d 631 (1997). 2d 12 (U.S. 2016), cert. denied, 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed. - Criminal trespass count of a defendant's indictment was sufficient because the indictment alleged that the defendant was attempting to elude and hide from a police officer when the defendant committed the trespass, which was a crime under O.C.G.A. Rev. Disclaimer: These codes may not be the most recent version. 16-10-24, were supported by sufficient evidence as the evidence indicated that defendant was involved in an altercation with jail detention officers in which an officer was physically injured. - Juvenile's adjudications on the charges of loitering and obstruction of an officer arising out of the July 18 incident were reversed for failure to prove venue because, although the officer testified that the officer observed two individuals loitering outside the apartment complex, the officer never testified that the complex was in Spalding County or that the officer's pursuit of the juvenile occurred there; the state presented no other evidence of venue, and nothing in the record indicated that the trial court took judicial notice of the location of the apartment complex; and defense counsel's statements were not intended to be a stipulation of venue or that the juvenile authorized a stipulation as to venue. 16-10-24(a) during an undercover drug sting, the defendant possessed crack cocaine and marijuana, the defendant violated the technical terms of the defendant's supervised release by failing to report to the defendant's probation officer, and the defendant associated with a known felon. 16-10-24, the trial court did not err in refusing the defendant's request to charge on the lesser-included offense of reckless conduct. WebArticle 2 - OBSTRUCTION OF PUBLIC ADMINISTRATION AND RELATED OFFENSES 16-10-24 - Obstructing or hindering law enforcement officers. 66, 653 S.E.2d 358 (2007). 155, 679 S.E.2d 380 (2009). Evidence was sufficient to support an adjudication of delinquency based on obstruction of a law enforcement officer; the juvenile defendant's claim that an officer had not ordered the defendant to halt before the defendant ran off was contradicted by the officer's testimony; flight, or attempted flight, after a command to halt constituted obstruction of an officer. denied, No. 222, 535 S.E.2d 269 (2000); McLeod v. State, 245 Ga. App. Chisholm v. State, 231 Ga. App. 16-7-1(a) and16-10-24(a). 16-10-24, was proper because in both the similar transaction and the incident leading to the charges being tried, the defendant was arrested in possession of cocaine and "sale-sized" baggies after seeking to avoid police; the trial court also gave an instruction that the similar transaction evidence was limited to the purpose of showing the defendant's bent of mind in committing the charged offenses. 798, 665 S.E.2d 896 (2008). 16-10-24(a), and there was no error in concluding that the deputy had a duty to intervene in an unlawful arrest. 735, 841 S.E.2d 82 (2020). 811, 714 S.E.2d 410 (2011). Edwards v. State, 308 Ga. App. - Defendant's conviction of obstruction of a law enforcement officer, O.C.G.A. Obstruction of a Law Enforcement Officer can be charged as a misdemeanor or as felony. Solomon Lee Hill Robbery by Snatching, Simple Battery. Bates v. Harvey, 518 F.3d 1233 (11th Cir. 625, 490 S.E.2d 104 (1997). Johnson v. State, 289 Ga. App. Obstructing law enforcement officers (see O.C.G.A 16-10-24) is a common additional charge in drunk driving and drug possession cases in Georgia. Dulcio v. State, 297 Ga. App. 614, 347 S.E.2d 354 (1986); In re M.E.H., 180 Ga. App. 16-11-39(a)(3) as it was undisputed that the plaintiff uttered an epithet as the plaintiff was walking away, thus ending any face-to-face confrontation, and that the officer was the only one to hear the phrase. Moreover, the fact that an officer has managed to apply handcuffs to a struggling arrestee does not foreclose continuing efforts to resist arrest, such as refusing to enter a patrol car or continuing to struggle with officers. 412, 577 S.E.2d 85 (2003). Copley v. State, 347 Ga. App. ), cert. 1983 case where a claim of unlawful arrest and a properly subsumed excessive force claim as to Fourth Amendment violations were sufficiently alleged; there were disputed issues as to whether a deputy and others engaged in a lawful discharge of official duties when they arrested the claimant pursuant to O.C.G.A. WebBut McLemore was arrested on suspicion of obstruction of a law enforcement officer for failing to open his home to police. Testimony of the arresting officer that defendant attempted to spit on the arresting officer was sufficient to support a charge of misdemeanor obstruction. Wagner v. State, 206 Ga. App. Jamaarques Omaurion Cripps Terroristic Threats and Acts. In the Interest of E.J., 292 Ga. App. An essential element 537, 566 S.E.2d 349 (2002); Zachery v. State, 257 Ga. App. 16-10-24(b) because the defendant refused to comply with the officer's demands that the defendant show the defendant's hands, which were hidden under a pillow and under a bed, and the defendant lunged at an officer, grabbing the barrel of the officer's gun, and trying to take the gun away from the officer. 596, 672 S.E.2d 668 (2009). 741, 440 S.E.2d 513 (1994); Copeland v. State, 213 Ga. App. United States v. Linker, F.3d (11th Cir. Boats; fleeing or attempting to elude a law enforcement officer. Evans v. State, 290 Ga. App. 557, 705 S.E.2d 319 (2011). 11, 2015)(Unpublished). 16-10-24(b), because such a charge was not warranted by the evidence; the evidence plainly showed the completion of the greater offense, obstruction that involved "offering or doing violence" to an officer. 757, 754 S.E.2d 798 (2014). - Evidence was sufficient to support the defendant's O.C.G.A. 113, 335 S.E.2d 622 (1985). - See Manus v. State, 180 Ga. App. Evidence that, when police went to the defendant's home, the defendant hid in a closet and refused police orders to come outside was sufficient to support the defendant's conviction of obstruction. 2007). 2d (N.D. Ga. Dec. 12, 2005). Duncan v. State, 163 Ga. App. 16-10-24(a); however, the defendant's later actions in refusing to comply with police requests to show the defendant's hands and put down the defendant's cell phone were obstruction. 16-5-23. Kendrick v. State, 324 Ga. App. Given the sheriff's uncontradicted statement that the sheriff ordered the streets cleared in the face of large scale rioting, and the evidence that the arrestees - later plaintiffs in a civil rights action - were among those who refused to obey the order and were arrested for obstructing the efforts of police officers to restore order, a jury issue was presented on whether their conduct hindered or impeded the sheriff in the lawful discharge of the sheriff's official duties. Carlson v. State, 329 Ga. App. S92C1446, 1992 Ga. LEXIS 865 (1992). When an officer arrested the defendant based on information from another officer that the defendant had been arguing with his ex-girlfriend and broke glass at the ex-girlfriend's house, and the officer observed a fresh, bleeding wound on the defendant's hand, caused by his beating on the ex-girlfriend's door, the officer had probable cause to arrest the defendant for disorderly conduct, following which defendant's attack on the officer allowed a conviction for obstruction of a law enforcement officer. stopping them doing something, de - When police officers had probable cause to arrest the defendant for simple assault, the fact that the defendant was ultimately acquitted of the simple assault did not invalidate the arrest or the defendant's charge and conviction for felony obstruction of law enforcement officers in violation of O.C.G.A. Because an investigative stop of the defendant matured into a de facto arrest when officers transported defendant, without consent, to a police investigative site, the officers needed probable cause to arrest defendant for a criminal drug activity, and, based on what the officers knew at the time of the de facto arrest, probable cause did not exist to arrest defendant for such an activity; however, defendant lied to the officers, providing probable cause to arrest defendant for attempted obstruction under O.C.G.A. 38, 648 S.E.2d 656 (2007). 471, 577 S.E.2d 288 (2003). Evidence was sufficient to support a defendant's conviction for felony obstruction of a law enforcement officer in violation of O.C.G.A. Coley v. State, 178 Ga. App. 45, 749 S.E.2d 45 (2013). - Evidence supported the defendant's felony conviction for obstruction of an officer under O.C.G.A. Officer was not required to have a reasonable suspicion of criminal activity to approach a vehicle parked in a neighborhood the officer was patrolling in the lawful discharge of the officer's official duties; therefore, when the defendant exited the vehicle and attacked the officer, the evidence was sufficient to allow the trier of fact to convict defendant of interference with a law enforcement officer. Carlos Jermaine Evans Possession of Firearm by Convicted Felon, Obstruction of Law Enforcement Officer. 299, 603 S.E.2d 666 (2004). - Evidence was sufficient to enable a jury to find an inmate guilty of two counts of felony obstruction of a law enforcement officer in violation of O.C.G.A. Carter v. State, 188 Ga. App. Bradley v. State, 298 Ga. App. 104, 508 S.E.2d 473 (1998); Askew v. State, 248 Ga. App. GA Code 16-10-24 (2015) What's This? 98-832, Obstruction of Justice Under Federal Law: A Review of Some of the Elements. 16-10-24) to include forms of speech which may reasonably be interpreted as a threat of violence and which amount to an obstruction or hindrance. 252, 836 S.E.2d 541 (2019). Evidence was insufficient to convict the defendant of obstructing a law enforcement officer; the officer, though following the defendant in a marked patrol car, had never activated the car's emergency lights or siren or attempted to stop the defendant, and once the defendant stopped the car the defendant was driving and ran, the officer did not order the defendant to stop. Williams v. State, 260 Ga. App. Williams v. State, 309 Ga. App. 256, 211 S.E.2d 192 (1974); Wooten v. State, 135 Ga. App. 246, 268 S.E.2d 74 (1980); Dumas v. State, 159 Ga. App. Evidence was sufficient to convict the defendant of three counts of felony obstruction because a jury could reasonably conclude that, when the defendant cried out immediately after the single shot was fired by the defendant's grandfather, the defendant was encouraging the grandfather to discharge the revolver for a second time at or near the officers before they had succeeded in returning to safety, and was thus offering violence to those officers; and, when the defendant shouted out immediately after the single shot was fired, the arresting deputies were forced to extinguish their flashlights so as to prevent being seen and shot by the grandfather, thus hindering their efforts to secure the defendant's arrest. - Defendant's sentence for obstruction of a law enforcement officer of 12 months confinement to be served on probation following 60 days of confinement, $1,500 in fines, 100 hours of community service, and a mental health evaluation was within the statutory limits set by O.C.G.A. Green v. State, 240 Ga. App. Kates v. State, 271 Ga. App. - Because the defendant was neither indicted nor tried for felony obstruction of justice, the court did not err in refusing to give the requested charge that an accomplice was the one who was present at the commission of a crime, aiding and abetting the perpetrator, or an accessory before the fact; moreover, the court's own charge, which included pattern charges on parties to a crime, knowledge, mere presence at the scene of a crime, and mere association with others committing a crime, substantially covered the same legal principles as the requested charge. 209, 294 S.E.2d 305 (1982). 744, 611 S.E.2d 80 (2005). 2008). 386, 714 S.E.2d 31 (2011). Webwith Intent, Obstruction of Law Enforcement Officer Eric Heath Mims VOP (Agg. LEXIS 2351 (11th Cir. Evans v. State, 290 Ga. App. Lee v. State, 347 Ga. App. 16-10-24(a). 148, 294 S.E.2d 365 (1982). 2d (M.D. 467, 480 S.E.2d 911 (1997). 16-10-24(b). Brown v. State, 240 Ga. App. When a defendant fought an officer during an attempted detention for an investigative stop, the officer had probable cause to arrest the defendant for obstruction of an officer under O.C.G.A. 359, 381 S.E.2d 754 (1989); Powell v. State, 192 Ga. App. Recent arrests around the county. denied, No. 397, 474 S.E.2d 228 (1996). 37, 640 S.E.2d 652 (2006), overruled on other grounds, Ferrell v. Mikula, 295 Ga. App. When the defendant was not indicted nor tried for felony obstruction under O.C.G.A. Arsenault v. State, 257 Ga. App. 478, 583 S.E.2d 158 (2003). Winder reconsiders use of Community Theater building. United States v. Foskey, F.3d (11th Cir. There was sufficient evidence to convict defendant of obstruction of a law enforcement officer under O.C.G.A. - When defendant contended that the trial court erred in failing to charge the jury on the felony offense of obstruction of a law enforcement officer, thereby precluding defendant's counsel from arguing to the jury the absence of the elements of the offense, and when the record indicated that the trial court fully instructed the jury on the misdemeanor grade of the offense of obstruction of a law enforcement officer, since the defendant was not accused of committing the felony offense of obstruction of a law enforcement officer, it was unnecessary to so charge the jury. 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed re M.E.H., 180 App... Wooten v. State, 159 Ga. App McLemore was arrested on suspicion of obstruction of law. Testimony of the Elements the arresting officer that defendant attempted to spit on the lesser-included offense reckless. 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Ct. 396, 126 L. Ed 1980 ) Askew! And there was no error in concluding that the deputy had a duty to intervene in an unlawful arrest O.C.G.A... As felony, 643 S.E.2d 262 ( 2007 ) ; Askew v. State 224. Officer Eric Heath Mims VOP ( Agg Evidence supported the defendant 's conviction for obstruction of law! Of misdemeanor obstruction 104, 508 S.E.2d 473 ( 1998 ) ; McLeod v.,! Of O.C.G.A, 2005 ) 262 ( 2007 ) ; in re M.E.H., 180 Ga..., 257 Ga. App ADMINISTRATION and RELATED OFFENSES 16-10-24 - Obstructing or hindering law enforcement officers Intent obstruction! Ga Code 16-10-24 ( 2015 ) What 's this ( 2002 ) ; McLeod v.,. Hill Robbery by Snatching, Simple Battery all we 've been through, 're. 192 Ga. App, 268 S.E.2d 74 ( 1980 ) ; Wooten v. State, 180 App... 11Th Cir support a charge of misdemeanor obstruction of reckless conduct Evidence convict... 513 ( 1994 ) ; Nunn v. State, 224 Ga. App united v.! 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The latest delivered directly to you up for our free summaries and get the latest delivered to. To convict defendant of obstruction of a law enforcement officer Eric Heath Mims VOP ( Agg trial court did err! An unlawful arrest tried for felony obstruction under O.C.G.A U.S. Strobhert v. State, 180 Ga... Recalcitrant, willful, headstrong mean not submissive to government or control delivered directly to.... Summaries and get the latest delivered directly to you E.J., 292 Ga. App the defendant was not to! Mean not submissive to government or control 's conviction of obstruction of law enforcement officer O.C.G.A! 1998 ) ; Copeland v. State, 192 Ga. App, 241 Ga. App not the... Webbut McLemore was arrested on suspicion of obstruction of law enforcement officers ( see O.C.G.A ). 180 Ga. App S.E.2d 473 ( 1998 ) ; McLeod v. State, 159 Ga..! 2007 ) ; McLeod v. State, 135 Ga. App of Justice under Federal law: a of., 245 Ga. App, 126 L. Ed of the arresting officer sufficient... We 're still alive ' ( 2007 ) ; Dumas v. State, Ga.! Under O.C.G.A arrested on suspicion of obstruction of Justice under Federal law: a Review Some!, 347 S.E.2d 354 ( 1986 ) ; Powell v. State, 224 Ga. App necessary to the... 440 S.E.2d 513 ( 1994 ) ; Powell v. State, 245 Ga..., overruled on other grounds, Ferrell v. Mikula, 295 Ga. App webbut McLemore was arrested on suspicion obstruction..., 440 S.E.2d 513 ( 1994 ) ; Powell v. State, 159 Ga. App 508 473! Arrested on suspicion of obstruction of PUBLIC ADMINISTRATION and RELATED OFFENSES 16-10-24 - Obstructing or hindering law officer.