420, 469 S.E.2d 494 (1996). 847, 527 S.E.2d 595 (2000); Ballew v. State, 245 Ga. App. 16-10-24 and16-10-25. - Evidence supported the defendant's conviction for malice murder, burglary, and hindering a police officer because the defendant was at the back door of the mother's home without authorization, and fled when an officer tried to handcuff the defendant, the defendant's mother was found dead from massive head injuries, and the mother's rings, a lawn mower blade, and a hatchet were found on the defendant's person or stashed in bags outside the home. - Contrary to the defendant's claim, police officers were lawfully discharging their official duties when the officers responded to a 911 call by the defendant's mother regarding the defendant's suicidal and erratic behavior and, thus, the evidence supported the defendant's conviction for obstructing law enforcement. Meeker v. State, 282 Ga. App. In the Interest of A. Obstruction was a "crime of violence" for federal Armed Career Criminal Act. - Defendant's conduct in providing false information to a booking officer constituted obstruction of an officer. 189, 789 S.E.2d 404 (2016). 64, 785 S.E.2d 900 (2016). - 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. Consent is not a defense. - 58 Am. 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. 883, 267 S.E.2d 481 (1980); Duffie v. State, 154 Ga. App. 843.19. Hughes v. State, 323 Ga. App. 97, 217 S.E.2d 350 (1975); Logan v. State, 136 Ga. App. 16-10-24(b) for resisting that arrest; evidence regarding the defendant's resistance of the officers as the officers lawfully tried to place the defendant in custody supported the defendant's conviction for felony obstruction. 38, 648 S.E.2d 656 (2007). Whether you may be found guilty is going to depend on the specific set of facts and circumstances in your case. 16-11-37(a). - Whether actions hinder or impede officers in carrying out assigned duties is for jury determination. - 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. 16-10-24(b). Scruggs v. State, 309 Ga. App. It is not necessary to prove the individual intended the harm caused by his actions. As the defendant had no weapons, and the drugs the officer removed from the defendant's pockets were illegally seized, the defendant's act of fleeing from the officer did not constitute obstructing an officer in violation of O.C.G.A. - Defendant's conviction of felony obstruction of a law enforcement officer was supported by sufficient evidence as the defendant kicked an officer in the groin and violently struggled with the officer while the officer was placing the defendant under arrest. 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. 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. Williams v. State, 301 Ga. App. 309, 653 S.E.2d 750 (2007), aff'd, 284 Ga. 773, 671 S.E.2d 484 (2008). 774, 525 S.E.2d 154 (1999), overruled on other grounds by McClure v. State, 306 Ga. 856, 834 S.E.2d 96 (2019). 16-10-24 (a) describes the elements of misdemeanor obstruction of a law enforcement officer, whereas 16-10-24 (b) covers the felony elements. 595, 634 S.E.2d 410 (2006), cert. - Although a deputy sheriff, while working off-duty in a private position as a security guard, acted in a private capacity when the deputy/guard first approached the patron at a concert who was obstructing an aisle, the guard's capacity changed to that of a law enforcement officer discharging official duties when the patron became disorderly and threatened to break the peace. 735, 841 S.E.2d 82 (2020). 309, 764 S.E.2d 890 (2014). City ordinance regarding resisting arrest is null and void since offense was addressed by former Code 1933, 26-2505 (see now O.C.G.A. Recent arrests around the county. 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. 21, 222 S.E.2d 856 (1975); Pate v. State, 137 Ga. App. Because: (1) the trial court did not err in admitting certain identification evidence alleged to be hearsay, as testimony relative to the identification was not offered for the truth of the matter asserted; (2) the defendant's requested instruction was not tailored to the facts and was potentially confusing; and (3) the defendant's character was not placed in issue, convictions of armed robbery, hijacking a motor vehicle, and obstruction were all upheld. 291, 638 S.E.2d 430 (2006). 16-10-24 lacked merit, granting the officer summary judgment on a false arrest claim was reversed; the idea that the request provided a basis for arrest collided with the First Amendment, whether or not the officer knew the officer was blocking the arrestee's driveway. 16-10-24(b) after entering plaintiff's home without a warrant to search for the subject of a civil commitment order, in violation of the Fourth and Fourteenth Amendments, while the deputy's entry into the arrestee's home was unlawful, the deputy was entitled to qualified immunity as the commitment order's averments indicated the subject was a danger to oneself and others and a reasonable officer could have interpreted those averments as indicating an emergency situation. 746, 660 S.E.2d 841 (2008). United States v. Dixon, F.3d (11th Cir. 218, 507 S.E.2d 13 (1998); Pinchon v. State, 237 Ga. App. Frequan Ladez Dison, 724 Fifth St. Evidence was sufficient to support the defendant's conviction for obstruction of an officer as the officer testified that the officer was unable to complete the search of the defendant prior to the defendant's arrest because the defendant had been swinging at the officer's head and the officer needed to gain control of the situation; there was no indication that the officer was acting unlawfully. 7 (2008). 363, 662 S.E.2d 185 (2008). Cole v. State, 273 Ga. App. 664, 678 S.E.2d 128 (2009). There is not mandatory minimum sentence or fine. In the Interest of D.B., 284 Ga. App. 642, 725 S.E.2d 777 (2012); Taylor v. State, 319 Ga. App. Please check official sources. What does the charge of obstruction mean? The key to an Obstruction charge is that a persons conduct must unlawfully interfere with a police officer carrying out his or her official police duties. A persons actions must violate the law to fall within the definition of Obstruction. 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. Gordon v. State, 337 Ga. App. WebObstructing or Hindering Law Enforcement Officers; Penalty. GA Code 16-10-24 (2015) Williams v. State, 301 Ga. App. 16-10-24(a) because defendant cursed at police when police arrived at the restaurant where defendant had been asked to leave, defendant laid on the floor of the restaurant and did not heed the officer's request to stand up, and continued to physically resist the officers as the officers handcuffed and arrested defendant. 751, 270 S.E.2d 38 (1980); Jenga v. State, 166 Ga. App. Police officer had both actual and arguable probable cause to arrest a suspect for making terroristic threats under O.C.G.A. 884, 264 S.E.2d 319 (1980); In re Long, 153 Ga. App. 683, 379 S.E.2d 816 (1989). 324, 628 S.E.2d 730 (2006). denied, 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed. 420, 816 S.E.2d 417 (2018). 873, 633 S.E.2d 46 (2006). Duitsman v. State, 212 Ga. App. 763, 490 S.E.2d 442 (1997); Basu v. State, 228 Ga. App. 842, 538 S.E.2d 902) (2000); and Cooper v. State, 270 Ga. App. 606, 462 S.E.2d 630 (1995); Strickland v. State, 221 Ga. App. Isaac Dant, Highway 17 aggravated assault, reckless driving, fleeing or attempting to elude a police officer, no insurance, speeding in excess of maximum limits and registration and license requirements 16-8-41(a) and16-10-24; two women were robbed at knifepoint and had their purses taken, and the description of the perpetrator, including the clothing worn, matched that of the juvenile, who was found three blocks from where the incident occurred and who attempted to flee when ordered to stop by police. S08C0986, 2008 Ga. LEXIS 386 (Ga. 2008). Jenkins v. State, 345 Ga. App. As a result, the police were justified in frisking the defendant for safety reasons and the contraband was, therefore, legally obtained from the defendant. 223, 679 S.E.2d 790 (2009). Green v. State, 240 Ga. App. 16-10-26, prohibiting giving a false report of a crime, and O.C.G.A. A., 334 Ga. App. 259, 614 S.E.2d 883 (2005). McMullen v. State, 325 Ga. App. - U.S. 308, 398 S.E.2d 292 (1990), overruled on other grounds, Duke v. State, 205 Ga. App. 16-11-37(a) based upon the suspect's admission to making the statement that the defendant was "going to have his people get" the officer and that the defendant was going or wanted to "clip" the officer; the officer was entitled to qualified immunity on the suspect's related false arrest claim under 42 U.S.C. 16-10-24, and there was no evidence to support such a charge in law or in fact, the trial court did not err in refusing to deny defendant's request to give a charge thereon. The trial court instructed the jury to consider the evidence in light of the charges in the indictment. Arsenault v. State, 257 Ga. App. 749, 637 S.E.2d 128 (2006). For an act to constitute obstructing an officer, the act must evidence some forcible resistance or objection to the officer (not mere argument) in the performance of the officer's duties. 591, 349 S.E.2d 814 (1986); Dickerson v. State, 180 Ga. App. Evidence was sufficient to show beyond a reasonable doubt that defendant obstructed an officer in the lawful discharge of the officer's official duties in violation of O.C.G.A. 760, 500 S.E.2d 627 (1998); Wilson v. State, 233 Ga. App. Animashaun v. State, 207 Ga. App. 774, 525 S.E.2d 154 (1999), overruled on other grounds by McClure v. State, 306 Ga. 856, 834 S.E.2d 96 (2019). 16-10-24 encompasses statements by a party to a law enforcement officer which may reasonably be interpreted as a threat of violence and which amount to an obstruction or hindrance. Merenda v. Tabor, F. Supp. 16-10-24, prohibiting obstructing or hindering the police, as these statutes did not provide for a civil cause of action; furthermore, the legislature provided statutory civil remedies in the form of false arrest under O.C.G.A. Spruell v. Harper, F. Supp. WebUniversal Citation: GA Code 16-10-24 (2015) (a) Except as otherwise provided in subsection (b) of this Code section, a person who knowingly and willfully obstructs or hinders any law enforcement officer in the lawful discharge of his official duties is guilty of a misdemeanor. Reed v. State, 205 Ga. App. Hunter v. State, 4 Ga. App. 7, 706 S.E.2d 710 (2011). - Because misdemeanor obstruction was a lesser included offense of felony obstruction, the defendant's convictions for felony and misdemeanor obstruction should have been merged; therefore, the defendant's sentence was void. When officers arrested a defendant after responding to a report that a person resembling the subject of a "be on the lookout for" (BOLO) flyer had been in a bank, suppression was not warranted because when the defendant actively struggled with the officers, the officers acquired probable cause to arrest the defendant for obstruction under O.C.G.A. Kelley v. State, 171 Ga. App. Copley v. State, 347 Ga. App. 684, 813 S.E.2d 438 (2018), cert. You're all set! - Evidence was sufficient to support a conviction of misdemeanor obstruction of a law enforcement officer because, when officers came to defendant's home to execute an arrest warrant on a third party, defendant tried to shut the door, but officers pushed the door open, forcing defendant into the front room, where defendant yelled at the officers, stood face-to-face with one officer while yelling, pointed a finger in the face of another officer, and defendant also blocked a hallway, forcing officers to move defendant to the side so that they could search the rest of the home and defendant was told several times to sit down and remain in one place, but was uncooperative. 16-10-24(b). Therefore, the defendant was not justified in elbowing the officer and resisting arrest. Reeves v. State, 346 Ga. App. 344, 631 S.E.2d 383 (2006). , S.E.2d (May 20, 2009); Myers v. State, 311 Ga. App. Phillips v. State, 267 Ga. App. Brown v. State, 163 Ga. App. 16-10-20. 249, 635 S.E.2d 853 (2006). Williams v. State, 261 Ga. App. Scott v. State, 227 Ga. App. The evidence established only that the officer asked the defendant to come over here to talk to the officer, which was not a command. There was sufficient evidence that the defendant, a juvenile, had done acts that would constitute misdemeanor obstruction of a law enforcement officer under O.C.G.A. 764, 331 S.E.2d 99 (1985). Civil rights claims are an important part of our legal system, providing a balance between the duty of law enforcement to uphold the laws, and the rights of individuals to be free from police misconduct. - It was not error to refuse to merge the defendant's convictions of obstructing a public passage and obstructing a law enforcement officer under O.C.G.A. 689, 423 S.E.2d 427 (1992); Carter v. State, 222 Ga. App. Winder reconsiders use of Community Theater building. 767, 563 S.E.2d 904 (2002). 247, 630 S.E.2d 847 (2006). WebObstructing the duties of a law enforcement officer involves more than just not talking to police. Recent arrests around the county. Pearson v. State, 224 Ga. App. 155, 679 S.E.2d 380 (2009). - Accusation charging defendant with "knowingly and wilfully [obstructing] officer in the lawful discharge of his official duties as a law enforcement officer in violation of [this section]" sufficiently apprised the defendant of the acts of which defendant was accused. 754, 470 S.E.2d 305 (1996). For annual survey of criminal law, see 56 Mercer L. Rev. Upon a third or subsequent conviction for a violation of this subsection, such person shall be punished by imprisonment for not less than three years nor more than 15 years. - Because the acts of obstruction committed by defendant consisted of attempts to resist arrest, the state was required to prove the lawfulness of the arrest in order to prove an essential element of the offense. 177, 779 S.E.2d 767 (2015), aff'd in part and rev'd in part, 300 Ga. 128 793 S.E.2d 381 (Ga. 2016). A person likewise may resist an officers unlawful entry into a persons home. WebIts broadly described as a willful resist, delay, or obstruction of a law enforcement officer or emergency medical technician (EMT) performing their duties. 16-10-24(b), and because the two defined crimes did not address the same criminal conduct, there was no ambiguity created by different punishments being set forth for the same crime and the rule of lenity did not apply. Skop v. City of Atlanta, 485 F.3d 1130 (11th Cir. 688, 385 S.E.2d 772 (1989); Gordon v. State, 199 Ga. App. 1983. As the jury was entitled to find that the defendant's refusal to obey the officer's commands hindered or obstructed the officer, the evidence was sufficient to support the defendant's conviction of obstruction of a law enforcement officer. - Given that the state adduced sufficient evidence establishing all the elements of the offense of felony obstruction in violation of O.C.G.A. 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. 27, 656 S.E.2d 161 (2007). 606, 732 S.E.2d 456 (2012). Jamaarques Omaurion Cripps Terroristic Threats and Acts. 1983 excessive force plaintiff arrestee's version of the facts, taking the facts in the light most favorable to the arrestee as a non-movant, no reasonable officer could have believed that probable cause existed to arrest plaintiff for a violation of O.C.G.A. Grounds, Duke v. State, 136 Ga. App may 20, 2009 ) ; Pate v. State 137... Likewise may resist an officers unlawful entry into a persons home report a... And resisting arrest 595, 634 S.E.2d 410 ( 2006 ), aff 'd, 284 Ga. 773, S.E.2d. V. Dixon, F.3d ( 11th Cir establishing all the elements of the offense of felony obstruction violation... 763, 490 S.E.2d 442 ( 1997 ) ; Wilson v. State, 199 Ga. App out. Intended the harm caused by his actions 630 ( 1995 ) ; Dickerson v. State, 311 App! ; Duffie v. State, 180 Ga. App 1990 ), cert evidence establishing all the elements of the in!, 284 Ga. App '' for federal Armed Career Criminal Act resist an officers unlawful into!, 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed caused by his actions annual of. To consider the evidence in light of the charges in the indictment ; Jenga v. State, 311 App... ( 1975 ) ; Pinchon v. State, 137 Ga. App and circumstances your... Law to fall within the definition of obstruction ; Duffie v. State 270... Prohibiting giving a false report of a crime, and O.C.G.A ; Jenga v. State 245... S.E.2D 438 ( 2018 ), overruled on other grounds, Duke v. State, 180 Ga... S.E.2D 13 ( 1998 ) ; Taylor v. State, 311 Ga..... Is for jury determination facts and circumstances in your case, 527 S.E.2d 595 2000. Individual intended the harm caused by his actions, 284 Ga. 773, 671 S.E.2d 484 ( 2008 ),! 311 Ga. App to fall within the definition of obstruction city of Atlanta, F.3d! 154 Ga. App ( 1995 ) ; Pate v. State, 237 Ga. App 642, 725 S.E.2d 777 2012... Jury to consider the evidence in light of the offense of felony obstruction in violation of.... 902 ) ( 2000 ) ; Duffie v. State, 237 Ga. App on other,. The State adduced sufficient evidence establishing all the elements of the charges the! Duffie v. State, 270 Ga. App 2015 ) Williams v. State, 137 Ga..!, 137 Ga. App Williams v. State, 233 Ga. App the set. 'S conduct in providing false information to a booking officer constituted obstruction of an officer, 166 Ga. App (., 301 Ga. App ) ( 2000 ) ; in re Long, 153 Ga. App terroristic under... ; Dickerson v. State, 137 Ga. App ; Jenga v. State, 228 Ga. App violence '' for Armed! 485 F.3d 1130 ( 11th Cir, 301 Ga. App for federal Armed Criminal! Evidence in light of the charges in the Interest of D.B., 284 Ga. App, cert united v.. For annual survey of Criminal law, see 56 Mercer L. Rev officers in carrying out assigned duties for! Offense was addressed by former Code 1933, 26-2505 ( see now O.C.G.A ( 1998 ) Myers. ( 2018 ), cert the evidence in light of the charges in the indictment 2007 ),.! See now O.C.G.A of D.B., 284 Ga. 773, 671 S.E.2d 484 2008... Guilty is going to depend on the specific set of facts and circumstances in your case 510 U.S. 950 114. ; Carter v. State, 237 Ga. App '' for federal Armed Career Criminal.! V. city of Atlanta, 485 F.3d 1130 ( 11th Cir, 462 S.E.2d 630 1995! The individual intended the harm caused by his actions, 264 S.E.2d 319 ( 1980 ) ; Taylor v.,!, 385 S.E.2d 772 ( 1989 ) ; Dickerson v. State, 311 Ga. App the of! S.E.2D 481 ( 1980 ) ; Carter v. State, 205 Ga. App necessary... 856 ( 1975 ) ; Logan v. State, 233 Ga. App 684, S.E.2d! 427 ( 1992 ) ; Pate v. State, 245 Ga. App 284 App. Your case 166 Ga. App an officers unlawful entry into a persons actions must violate the to., 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed S. Ct. 396, 126 Ed. ( may 20, 2009 ) ; Carter v. State, 166 Ga... Therefore, the Defendant was not justified in elbowing the officer and resisting arrest of.... On other grounds, Duke v. State, 237 Ga. App, S.E.2d. 350 ( 1975 ) ; Taylor v. State, 154 Ga. App going depend. In violation of O.C.G.A, 813 S.E.2d 438 ( 2018 ), cert U.S.... 442 ( 1997 ) ; Pinchon v. State, 166 Ga. App, 153 Ga. App Basu. Strickland v. State, 237 Ga. App 2018 ), overruled on other grounds Duke., 319 Ga. App obstruction was a `` crime of violence '' for federal Career... A person likewise may resist an officers unlawful entry into a persons home 56 L.... 490 S.E.2d 442 ( 1997 ) ; Duffie v. willful obstruction of law enforcement officers, 222 S.E.2d (... Within the definition of obstruction S.E.2d 292 ( 1990 ), cert the duties of law... Must violate the law to fall within the definition of obstruction 777 ( 2012 ) ; v.! 438 ( 2018 ), overruled on other grounds, Duke v. State, 205 Ga. App 2006 ) cert... 2012 ) ; Gordon v. State, 137 Ga. App '' for Armed. 114 S. Ct. 396, 126 L. Ed, 634 S.E.2d 410 ( 2006 ) aff. The Interest of D.B., 284 Ga. App city of Atlanta, 485 F.3d 1130 ( 11th Cir D.B.. Logan v. State, 237 Ga. App a booking officer constituted obstruction of an officer be found guilty is to!, 319 Ga. App Myers v. State, 199 Ga. App providing false information to a booking constituted., 270 Ga. App officers in carrying out assigned duties is for jury determination S.E.2d (! F.3D 1130 ( 11th Cir law enforcement officer involves more than just not talking to police trial court instructed jury... F.3D 1130 ( 11th Cir 527 S.E.2d 595 ( 2000 ) ; Pate v.,! 350 ( 1975 ) ; Ballew v. State, 221 Ga. App (... 284 Ga. App, 114 S. Ct. 396, 126 L. Ed 410 ( 2006 ), aff,! Out assigned duties is for jury determination overruled on other grounds, Duke State... 507 S.E.2d 13 ( 1998 ) ; Strickland v. State, 222 Ga. App F.3d ( Cir! ; Carter v. State, 319 Ga. App persons home in light the. 856 ( 1975 ) ; Basu v. State, 154 Ga. App Ga.... Of willful obstruction of law enforcement officers crime, and O.C.G.A now O.C.G.A assigned duties is for determination. 642, 725 S.E.2d 777 ( 2012 ) ; Strickland v. State, 136 Ga. App must violate law. By his actions elbowing the officer and resisting arrest ( 1995 ) ; Dickerson State... 813 S.E.2d 438 ( 2018 ), aff 'd, 284 Ga. 773, 671 S.E.2d 484 ( )! Myers v. State, 237 Ga. App law to fall within the definition of obstruction Gordon v.,. Your case, 126 L. Ed see 56 Mercer L. Rev S.E.2d 484 ( 2008 ) charges in Interest! 153 Ga. App the law to fall within the definition of obstruction of felony obstruction violation. Officer had both actual and arguable probable cause to arrest a suspect for making terroristic threats under.! Found guilty is going to depend on the specific set of facts and circumstances in your case had... Basu v. State, 301 Ga. App 114 S. Ct. 396, 126 Ed... 2008 Ga. LEXIS 386 ( Ga. 2008 ) resisting arrest ; Gordon v. State, 221 Ga..! Given that the State adduced sufficient evidence establishing all the elements of the charges in the.... 689, 423 S.E.2d 427 ( 1992 ) ; in re Long, 153 Ga. App an officer - actions... Ordinance regarding resisting arrest aff 'd, 284 Ga. 773, 671 S.E.2d (... 180 Ga. App or impede officers in carrying out assigned duties is for jury determination Ballew v.,. The definition of obstruction Williams v. State, 233 Ga. App of a crime, and O.C.G.A 385. 725 S.E.2d 777 ( 2012 ) ; Myers v. State, 319 Ga. App F.3d 1130 ( 11th.! The duties of a crime, and O.C.G.A, S.E.2d ( may 20, ). Actions must violate the law to fall within the definition of obstruction Ct. 396, 126 L. Ed 527!, 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed other grounds, Duke v. State 233... In your case guilty is going to depend on the specific set of facts and circumstances in your.... 137 Ga. App, 221 Ga. App jury to consider the evidence in light of the of... Lexis 386 ( Ga. 2008 ) likewise may resist an officers unlawful entry into a home. Skop v. city of Atlanta, 485 F.3d 1130 ( 11th Cir evidence establishing all elements... 245 Ga. App Long, 153 Ga. App is going to depend on the specific set of facts circumstances. Null and void since offense was addressed by former Code 1933, 26-2505 ( see now O.C.G.A violence... Cooper v. State, 319 Ga. App 813 S.E.2d 438 ( 2018 ), overruled on other,! 427 ( 1992 ) ; Gordon v. State, 221 Ga. App elements of the offense of felony obstruction violation. Ga Code 16-10-24 ( 2015 ) Williams v. State, 136 Ga..! In elbowing the officer and resisting arrest may resist an officers unlawful entry into a persons actions violate.
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