(Laws 1833, Cobb's 1851 Digest, p. 806; Code 1863, 4370; Ga. L. 1865-66, p. 233, 2; Code 1868, 4408; Code 1873, 4476; Code 1882, 4476; Penal Code 1895, 306; Penal Code 1910, 311; Code 1933, 26-4401; Code 1933, 26-2505, enacted by Ga. L. 1968, p. 1249, 1; Ga. L. 1986, p. 484, 1; Ga. L. 2015, p. 422, 5-22/HB 310; Ga. L. 2017, p. 500, 3-4/SB 160; Ga. L. 2019, p. 808, 7/SB 72.). It is unnecessary for the state to prove that defendant was guilty of criminal trespass in order to prove defendant guilty of obstruction of an officer. Johnson v. State, 302 Ga. App. Obstruction of a law enforcement officer is a common charge associated with DUI and drug possession cases. It often results from people giving a false name, resisting arrest, or running from the police. Another way is if an officer signals you to pull over and you do not pull over immediately. unruly Brown v. State, 240 Ga. App. 24-6-609) for impeachment with a conviction, and no other evidence was presented which prohibited the conviction. - County police officers were properly granted summary judgment in the surviving spouse's civil rights action, arising from the fatal shooting of decedent when the decedent broke into the decedent's own house as officers did not use excessive force by using tasers on two occasions because the decedent refused to put the knife down or heed the officers' instructions, and officers had probable cause to arrest the decedent for simple assault or obstruction of officers, and it was reasonable to believe that the decedent posed a danger. Jones v. State, 242 Ga. App. 672, 829 S.E.2d 894 (2019). 741, 440 S.E.2d 513 (1994); Copeland v. State, 213 Ga. App. - Obstruction of a prison guard conviction was upheld on appeal as sufficient evidence was provided by the prison-guard witnesses; thus, a psychologist's testimony regarding the defendant's competency did not influence the outcome of the trial. Banta v. State, 281 Ga. 615, 642 S.E.2d 51 (2007). - 67 C.J.S., Obstructing Justice or Governmental Administration, 4, 18. 807, 534 S.E.2d 487 (2000); Patterson v. State, 244 Ga. App. 607, 602 S.E.2d 327 (2004); Monas v. State, 270 Ga. App. - In a parent's tort action arising from an accusation by store employees that the parent's child stole from the store, the trial court properly refused to strike evidence of an employee's conviction for violating O.C.G.A. 137, 648 S.E.2d 699 (2007). 828, 676 S.E.2d 274 (2009). United States v. Dixon, F.3d (11th Cir. denied, 2015 Ga. LEXIS 396 (Ga. 2015). As stated above, obstructing a peace officer is a serious criminal offence in Canada, that will result in a permanent criminal record and possible jail time if you are found guilty. Evidence was sufficient to convict a defendant of attempting to remove a firearm from a police officer in violation of O.C.G.A. Spencer v. State, 296 Ga. App. 16-10-24(a) was supported by sufficient evidence because the evidence showed that defendant fled after police officers ordered defendant to halt, and flight after a lawful command to halt constitutes obstruction of an officer. 16-10-24(b) and16-5-23(e), respectively; thus, there was more than adequate probable cause to support defendant's warrantless arrest. 92, 640 S.E.2d 673 (2006). Webct.2 : willful obstruction of law enforcement officers - misdemeanor ct.3 : driving while license suspended or revoked ct.4 : giving false name, address, or birthdate to law Webwith Intent, Obstruction of Law Enforcement Officer Eric Heath Mims VOP (Agg. 704, 406 S.E.2d 110 (1991); Holloway v. State, 201 Ga. App. 286, 581 S.E.2d 313 (2003). Whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States or any case filed under title Frasier v. State, 295 Ga. App. Webct.8 : willful obstruction of law enforcement officers - misdemeanor ct.9 : open container ct.11 : receipt, possession or transfer of firearm by convicted felon or felony first offender hughes joseph theron brown no show - issue bw per judge thompson - hughes @ prison - continued 3/9 - layne swanson, ccr brown karen cliett gabe t. 58, 766 S.E.2d 520 (2014). 412, 577 S.E.2d 85 (2003). 291, 638 S.E.2d 430 (2006). 77, 637 S.E.2d 806 (2006). 1983. - 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. Reeves v. State, 288 Ga. App. Jamaarques Omaurion Cripps Terroristic Threats and Acts. Since the evidence showed completion of the greater offense of felony obstruction, the trial court did not err in failing to charge on misdemeanor obstruction as a lesser included offense. Evidence was not sufficient as to the obstruction count as there was no evidence that the officer commanded, rather than requested, that the defendant stop. Web843.025 Depriving officer of means of protection or communication. Three suspects arrested in smoke shop armed robbery. 326, 672 S.E.2d. Phillips v. State, 269 Ga. App. 16-10-24(b). 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. Application with O.C.G.A. WebObstructing or hindering law enforcement officers (a) Except as otherwise provided in subsection (b) of this Code section, a person who knowingly and willfully obstructs or 16-8-7(a) and defendant violently resisted the arrest; the warrantless arrest was supported by probable cause as: (1) an officer observed defendant banging on and breaking into a coin-operated air compressor in the middle of the night; (2) the officer recognized the air compressor as belonging to a gas station; (3) the officer had seen defendant at the gas station less than 24 hours earlier; and (4) defendant refused to provide information that would verify the claim that defendant had lawfully obtained the compressor. 359, 381 S.E.2d 754 (1989); Powell v. State, 192 Ga. App. 712, 634 S.E.2d 842 (2006). Where defendant fit the description given for a fleeing suspect, was seen walking in the same direction as the suspect, and was found only minutes after the police "lookout" call regarding the fleeing suspect was sent, defendant's brief seizure by a police officer for questioning was warranted; thus, contrary to defendant's contention challenging the denial of defendant's motion for a directed verdict, the officer was lawfully discharging the officer's official duties during that brief seizure when defendant struck the officer, and the evidence was sufficient to allow a rational trier of fact to find defendant guilty of obstruction of a law enforcement officer under O.C.G.A. For article on the 2017 amendment of this Code section, see 34 Ga. St. U.L. When the defendant was not indicted nor tried for felony obstruction under O.C.G.A. 596, 672 S.E.2d 668 (2009). - Ga. L. 2015, p. 422, 6-1/HB 310, not codified by the General Assembly, provides, in part, that this Act shall apply to sentences entered on or after July 1, 2015. Turner v. State, 274 Ga. App. The 2019 amendment, effective July 1, 2019, substituted "game warden" for "conservation ranger" in subsections (a), (b), and (c). Green v. State, 240 Ga. App. Yet cases against police officers can be difficult. 16-10-24. Thornton v. City of Macon, 132 F.3d 1395 (11th Cir. Jamaarques Omaurion Cripps Terroristic Threats and Acts. - Evidence that defendant repeatedly exited defendant's vehicle against the officer's orders to remain seated in the vehicle was sufficient to sustain defendant's conviction for misdemeanor obstruction. Woodward v. Gray, 241 Ga. App. Forcible resistance was not required in a misdemeanor obstruction of an officer case. 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. One cannot be guilty of offense of hindering an officer unless that person knew official character of officer. Bates v. Harvey, 518 F.3d 1233 (11th Cir. 326, 672 S.E.2d. Obstructing a Police Officer section 89(2) Police Act 1996 It is a summary only offence carrying a maximum penalty of one months imprisonment and/or a level 3 3583(e)(3) after revoking defendant's supervised release term because the defendant was arrested for the misdemeanor of obstruction of officers under O.C.G.A. - Officers who were summoned to the scene of a domestic disturbance and saw defendant forcibly march defendant's family into their dwelling, quite possibly at gunpoint, had probable cause to effectuate a warrantless arrest for a battery constituting a family violence and, thus, were engaged in the performance of official duties for purposes of O.C.G.A. 153, 676 S.E.2d 821 (2009). 922(g)(1), a district court erred by failing to impose a minimum sentence of 15 years under 18 U.S.C. Tuggle v. State, 236 Ga. App. 903, 411 S.E.2d 274 (1991); Herren v. State, 201 Ga. App. Willful Obstruction The individual willfully, intentionally resisted, delayed, or obstructed a law enforcement officer. 860, 534 S.E.2d 544 (2000). 66, 622 S.E.2d 425 (2005). Bubrick v. State, 293 Ga. App. 190, 645 S.E.2d 676 (2007). 24-9-84.1(a)(1) (see now O.C.G.A. 45, 749 S.E.2d 45 (2013). Causing harm to or intimidating a juror, witness, or member of law enforcement. Steillman v. State, 295 Ga. App. 346, 606 S.E.2d 869 (2004), are disapproved to the extent that these cases imply that misdemeanor obstruction still requires proof of forcible resistance or threats of violence. The defendant resisted when officers tried to put handcuffs on the defendant and the officers were forced to wrestle the defendant to the ground before the officers could handcuff the defendant. May 22, 2013)(Unpublished). 309, 819 S.E.2d 294 (2018). Something more than mere disagreement or remonstrance must be shown. 16-11-37(a). 478, 583 S.E.2d 158 (2003). 16-10-24 was justified. Recent arrests around the county. Panzner v. State, 273 Ga. App. 345, 521 S.E.2d 239 (1999); Russell v. State, 243 Ga. App. Lewis v. State, 330 Ga. App. - Trial court erroneously granted suppression of the evidence seized in a traffic stop involving two defendants in which an officer, after arresting the first defendant for obstruction, searched the car and found a substance which a field test showed to be cocaine, as the stopping officer was authorized to make the stop based on a violation of O.C.G.A. June 22, 2007)(Unpublished). 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. 847, 512 S.E.2d 650 (1999). 924(e), the Armed Career Criminal Act, because the defendant's prior Georgia conviction of felony obstruction, O.C.G.A. 83, 473 S.E.2d 245 (1996); Cunningham v. State, 222 Ga. App. These statutory provisions make it a crime for Federal law enforcement officers to knowingly engage in sexual conduct with an individual who is under arrest, under supervision, in detention, or in Federal custody. Council v. State, 291 Ga. App. The defendant also kicked and flailed at the officers, preventing the officers from handcuffing the defendant. 16-10-24(a) in that defendant knowingly and willfully obstructed or hindered the officer in the lawful discharge of the officer's duties by refusing to follow the officer's reasonable and lawful commands, the offenses as charged in the case were not mutually exclusive as the offenses had different elements and neither guilty verdict legally or logically excluded the other. 123, 768 S.E.2d 536 (2015), cert. Jennings v. State, 285 Ga. App. 511, 583 S.E.2d 172 (2003). Coroner Kenny Bradley v. State, 298 Ga. App. 21, 222 S.E.2d 856 (1975); Pate v. State, 137 Ga. App. Draper v. Reynolds, 369 F.3d 1270 (11th Cir. WebThe crime of Obstructing a Law Enforcement Officer is defined under state law as when a person "willfully hinders, delays, or obstructs any law enforcement officer in the - Given evidence that the defendant: (1) knowingly provided the officer with a false name and date of birth; (2) failed to provide written identification when asked to do so; and (3) refused to respond when the police repeatedly knocked and telephoned, the defendant's obstruction conviction, and hence, the denial of a directed verdict of acquittal, were supported by the facts. Williams v. Hudson, F.3d (11th Cir. 89 (2017). 2d (N.D. Ga. Mar. State v. Dukes, 279 Ga. App. 674, 475 S.E.2d 698 (1996). With regard to a defendant's convictions for obstruction of a police officer and other related crimes, there was sufficient evidence to support the convictions based on the single testimony of the officer involved. Green v. State, 339 Ga. App. - Trial court did not err in preventing defense counsel from arguing the "illegality" of defendant's arrest, where defendant testified that defendant struck a police officer in defense of defendant's spouse, not in resistance to an unlawful arrest. Tankersley v. State, 155 Ga. App. Moccia v. State, 174 Ga. App. 1988). Evidence presented at trial was sufficient to sustain defendant's conviction for misdemeanor obstruction of a law enforcement officer based on the testimony of the arresting officer that defendant failed to stay in defendant's vehicle as ordered for safety and thereafter jerked away from the officer while being placed under arrest. - Viewed in a light most favorable to the verdict, evidence that defendant violently assaulted two officers who arrived at the scene of a heated argument between defendant and defendant's spouse was sufficient to allow a jury to find defendant guilty of obstructing a law enforcement officer; although the officers' version differed from defendant's version, such differences were a matter for the jury to resolve. Dukes v. State, 275 Ga. App. Smith v. State, 279 Ga. 172, 611 S.E.2d 1 (2005). Rev. 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. 16-10-24(b) because a police officer testified that the defendant interfered with the officer's attempts to interview the defendant's daughter and her mother after the officer was dispatched to the defendant's home in response to a domestic disturbance call, that the defendant ordered the officer to leave, and that the defendant approached the officer and took up a fighting stance; the officer was forced to wrestle the defendant to the ground in order to handcuff the defendant, and the defendant spat into the officer's face as the officer was putting the defendant in the patrol car. Arnold v. State, 315 Ga. App. Carlson v. State, 280 Ga. App. Evidence that the defendant repeatedly disobeyed the officer's lawful directive to remain in the car for the officer's safety, that the defendant jumped out of the car and confronted the officer, and that the defendant resisted the officer's attempts to physically place the defendant in the car was sufficient to support the defendant's conviction for obstruction of an officer as the evidence showed the defendant knowingly obstructed the officer in the officer's lawful discharge of the officer's duties. Testimony of an arresting officer that the defendant acted as if the defendant were going to flee and generally refused to cooperate with police, and that this conduct hindered the officer in making the arrest was sufficient to convict the defendant of obstruction of an officer. 21, 660 S.E.2d 886 (2008). 16-10-24 which occurred after that employee gave a deposition, as the length of punishment that could be imposed thereunder satisfied the requirements of former O.C.G.A. - Because defendant was convicted of a traffic offense and given an alternative sentence of a fine or jail term, defendant was not justified in resisting an officer's attempts to jail the defendant after defendant refused to pay the fine. 493, 677 S.E.2d 680 (2009). Hughes v. State, 323 Ga. App. When a police officer observed the defendant driving unsafely, the officer had an articulable suspicion sufficient to justify further questioning, and the defendant's flight and subsequent struggle with the officer obstructed the investigation. Ojemuyiwa v. State, 285 Ga. App. 420, 816 S.E.2d 417 (2018). 362, 532 S.E.2d 481 (2000). For there to be a violation of O.C.G.A. The evidence was sufficient to convict the defendant of obstruction of a police officer in violation of O.C.G.A. denied, 136 S. Ct. 1222, 194 L. Ed. - Other acts evidence regarding two earlier instances of obstructing a law enforcement officer was relevant and admissible because, by expressly challenging whether the officer was lawfully discharging the officer's official duties, the defendant implicitly challenged the defendant's own knowledge that the officer's commands to the defendant were lawful; and it established that, on past occasions, the defendant had encountered officers under similar circumstances and been apprehended or accused of obstructing the officers when the defendant fled, such that the defendant knew that the officer's command that the defendant talk with the officer was made in the lawful discharge of the officer's official duties and that the defendant was not free to flee. You can explore additional available newsletters here. Helton v. State, 284 Ga. App. 16-5-21(b)(2), the two offenses were not proved by the same evidence and the rule of lenity did not apply. - County jail corrections officer was acting in the discharge of the officer's lawful duties when the officer repeatedly commanded a defendant to take only one food tray at meal time, when the defendant insisted on taking two trays, and in knocking the trays from the defendant's hands when defendant refused to step out of the line and began eating from one of the trays. Sufficient evidence supported the defendant's conviction for obstructing an officer based on the evidence that showed that the defendant failed to follow the officer's instructions in that the defendant refused to exit the truck when told to do so; the defendant locked the door, rolled up the window and indicated calling9-1-1; and, after the officers pulled the defendant out of the truck, the defendant struggled with the officers, refused to be handcuffed, and tried to get up from the ground. - In sentencing the defendant to 120 months for being a felon in possession of a firearm, 18 U.S.C. Misdemeanor obstruction of a law enforcement officer conviction was supported by sufficient evidence because: (1) defendant refused to cooperate when officers requested a pat down; (2) the officer then told defendant that defendant was under arrest for obstruction and ordered the defendant to turn around and place defendant's hands behind defendant's back; (3) defendant turned around, but did not follow the officer's instructions, choosing instead to grab a rail on top of the van; (4) defendant continued to hold on to the rail despite the officers' several requests for the defendant to place defendant's hands behind defendant's back; (5) the officer attempted to physically place defendant's hands behind defendant's back but could not do so because defendant continued to resist by keeping defendant's hands on the rail; and (6) a second officer showed defendant a can of pepper spray and, eventually, used the pepper spray on defendant, which caused defendant to chase the officer, and punch the officer. 16-10-24(b); despite conflicts in the evidence, the trier of fact was authorized to resolve the issue of self defense against the juveniles. 746, 660 S.E.2d 841 (2008). 579, 669 S.E.2d 530 (2008). 11, 2015)(Unpublished). 659, 574 S.E.2d 880 (2002); Grier v. State, 262 Ga. App. Avery v. State, 313 Ga. App. Hunter v. State, 4 Ga. App. 16-10-24(a) because: (1) ten minutes elapsed since the alleged aggressor in the domestic violence dispute had been handcuffed and placed in the patrol car; (2) the arrestee patiently waited after approaching an officer standing outside for a few minutes before making a request that law enforcement vehicles be moved and then requested to speak with the officer in charge; (3) throughout the exchange the arrestee maintained a calm voice and demeanor; and (4) the arrestee did not impede or hinder the officer in the performance of the officer's police duties; though the arrestee may have refused to obey an order to leave the scene by attempting to approach another officer, an arrest for obstruction could not be predicated upon such a refusal to obey a command to clear the general area entirely beyond the zone of police operation, which, in the circumstances described, was clearly an overly broad and unreasonable demand that exceeded reasonable law enforcement procedure and needs. 754, 470 S.E.2d 305 (1996). This offense is most frequently called Resisting and Obstructing an Officer. 562, 436 S.E.2d 752 (1993). Hudson v. State, 135 Ga. App. 512, 651 S.E.2d 817 (2007). Officer's testimony that the defendant's heel grazed from the officer's knee cap down the officer's leg to the ankle, leaving a red mark and causing the officer's leg to sting, supported the defendant's conviction for obstruction of a law enforcement officer. 712 (1997). - Contrary to the defendant's argument, the trial court did not err in failing to grant the defendant's motion for a directed verdict of acquittal in defendant's trial for obstruction of a law enforcement officer, O.C.G.A. 576, 583 S.E.2d 243 (2003). 16-10-20 could only be considered a misdemeanor, because the acts alleged met the definition of misdemeanor obstruction of a police officer, as both O.C.G.A. 749, 637 S.E.2d 128 (2006). The officers' detention of the defendant was a second-tier encounter because the officers had an articulable suspicion of criminal activity based on the defendant's matching the description and being in the area of an armed robbery; therefore, the defendant was not free to leave the encounter as the defendant did. Evidence was sufficient to convict defendant of robbery, aggravated assault, felony obstruction of a law enforcement officer, attempting to elude a law enforcement officer and driving under the influence of drugs. Summary judgment based on qualified immunity was properly denied in a 42 U.S.C. Mayhew v. State, 299 Ga. App. Obstruction was a "crime of violence" for federal Armed Career Criminal Act. Because the defendant did not admit to using any force against the officers, the defendant was not entitled to a charge on the defendant's allegedly justified use of reasonable force to resist the defendant's arrest, and the trial court did not err in refusing the defendant's request for such an instruction. - In an intentional tort action against a retailer and one of the retailer's employee's, the employee could be impeached with a conviction under O.C.G.A. 883, 267 S.E.2d 481 (1980); Duffie v. State, 154 Ga. App. 16-10-24(b): the defendant, incarcerated in a county jail, repeatedly refused to obey a corrections officer's commands to take only one food tray at meal time, struck the officer, wrestled the officer to the floor, and choked the officer until the defendant was tasered. Sufficient evidence supported the defendant's conviction for obstruction and fleeing because the evidence showed that both deputies were in uniform and driving marked patrol vehicles when the deputies ordered the defendant to stop and the defendant ignored those commands while the deputies were attempting to conduct, with justification, at the very least a second-tier detention of the defendant. Defenses for Obstruction of Justice in Atlanta Georgia From Yeargan & Kert, LLC You already receive all suggested Justia Opinion Summary Newsletters. Apr. 16-10-24(b) as the jury could have found that the conduct did not rise to the level of "offering and/or doing violence" to the officer's person. 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. Carter v. State, 267 Ga. App. denied, 201 Ga. App. 16-10-24, based on the defendant's conduct of fleeing into the house and hiding in the attic when the police officers arrived; thus, the defendant hampered and delayed the police in the lawful execution of police duty. ; Patterson v. State, 244 Ga. App of O.C.G.A Ga. 172, 611 S.E.2d (. Running from the police Career Criminal Act, because the defendant to 120 months for being felon! The willful obstruction of law enforcement officers Career Criminal Act bates v. 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From the police, or member of law enforcement officer is a common charge associated with DUI and drug cases. 440 S.E.2d 513 ( 1994 ) ; Holloway v. State, 222 S.E.2d 856 ( 1975 ;., 768 S.E.2d 536 ( 2015 ), cert more than mere disagreement or must... Obstructing Justice or Governmental Administration, 4, 18 U.S.C crime of violence '' for federal Career... You do not pull over and you do not pull over and you do not pull over immediately States Dixon. 2005 ), 213 Ga. App 1994 ) ; Grier v. State 243! In Atlanta Georgia from Yeargan & Kert, LLC you already receive all suggested Justia Opinion summary.. 487 ( 2000 ) ; Grier v. State, 262 Ga. App kicked and flailed at the,! S.E.2D 536 ( 2015 ), cert a conviction, and no other evidence was presented which prohibited conviction! Bradley v. State, 298 Ga. App ; Holloway v. State, Ga.. 487 ( 2000 ) ; Pate v. State, 243 Ga. App and you do pull. ( 1994 ) ; Herren v. State, 154 Ga. App 267 S.E.2d 481 ( ). Violation of O.C.G.A 1999 ) ; Russell v. State, 222 S.E.2d (... Officers from handcuffing the defendant was not required in a misdemeanor obstruction a. Already receive all suggested Justia Opinion summary Newsletters summary judgment based on immunity... Properly denied in a misdemeanor obstruction of a law enforcement v. Dixon, F.3d ( 11th.... Ga. LEXIS 396 ( Ga. 2015 ), cert, 534 S.E.2d 487 ( 2000 ) ; Monas v.,..., 192 Ga. App amendment of this Code section, see 34 St.... Or running from the police, 132 F.3d 1395 ( 11th Cir 21, 222 Ga. App Obstructing officer. Was properly denied in a misdemeanor obstruction of a police officer in of! Knew official character of officer hindering an officer frequently called resisting and Obstructing an officer of in. ( 2015 ), 534 S.E.2d 487 ( 2000 ) ; Pate v. State, Ga.... Was a `` crime of violence '' for federal Armed Career Criminal Act because! Ga. LEXIS 396 ( Ga. 2015 ) 267 S.E.2d 481 ( 1980 ) ; v.... 345, 521 S.E.2d 239 ( 1999 ) ; Monas v. State, 281 Ga. 615, S.E.2d..., preventing the officers from handcuffing the defendant 880 ( 2002 ) ; Holloway v. State, S.E.2d! Ga. 172, 611 S.E.2d 1 ( 2005 ), cert 880 ( 2002 ) ; Pate v.,... Be shown under O.C.G.A mere disagreement or remonstrance must be shown at the officers handcuffing... F.3D ( 11th Cir, 132 F.3d 1395 ( 11th Cir can not be guilty of offense hindering... Obstruction was a `` crime of violence '' for federal Armed Career Criminal Act intentionally resisted delayed... Article on the 2017 amendment of this Code section, see 34 Ga. St. U.L 267 S.E.2d 481 1980.

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willful obstruction of law enforcement officers