McClary v

State, 292 Ga. App. 184, 663 S.E.2d 809 (2008). An officer had probable cause to arrest the defendant for disorderly conduct, O.C.G.A. § 16-11-39, based on the defendant’s yelling obscenities at the officer. Therefore, the defendant’s claim that the defendant was entitled to a directed verdict on charges of misdemeanor obstruction of an officer because the defendant was resisting an unlawful arrest was without merit. Steillman v. State, 295 Ga. App. 778, 673 S.E.2d 286 (2009). When an initial stop was lawful and the defendant failed to stop when ordered to do so, there was probable cause to believe O.C.G.A. § 16-10-24(a) was violated and the defendant’s apprehension and arrest did not violate the Fourth Amendment. United States v. Foskey, No. 10-15221, 2012 U.S. App. LEXIS 374 (11th Cir. Jan. 9, 2012), cert. denied, U.S. , 133 S. Ct. 460, 184 L. Ed. 2d 283 (2012) (Unpublished). When a deputy arrested an arrestee for being drunk at a high school football game, the deputy was entitled to qualified immunity as to the arrestee’s excessive force claim because, inter alia, probable cause or arguable probable cause existed for the deputy to arrest the arrestee for obstructing a law enforcement officer under O.C.G.A. § 16-10-24(a) since the facts and circumstances would cause a prudent person to believe that the arrestee’s negative responses to questions about drinking were intentional lies or, at least, constituted stubborn obstinance. Collins v. Ensley, 498 Fed. Appx. 908 (11th Cir. 2012) (Unpublished). 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. § 16-10-24. United States v. Akinlade, No. 11-15840, 2013 U.S. App. LEXIS 10270 (11th Cir. May 22, 2013) (Unpublished). Fatal shooting of decedent pending arrest for assault. — 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. Smith v. LePage, 834 F.3d 1285 (11th Cir. 2016). Pushing officer trying to handcuff defendant was sufficient evidence. — Pushing the officer when the officer tried to handcuff a defendant was sufficient to support O.C.G.A. § 16-10-24(a) misdemeanor obstruction of an officer. McCarty v. State, 269 Ga. App. 299, 603 S.E.2d 666 (2004). Shoving and failing to obey orders sufficient for conviction. — Defendant’s conviction of obstruction of a law enforcement officer, O.C.G.A. § 16-10-24(a), was proper because the evidence showed that the defendant shoved a deputy and failed to obey orders made by the deputy in efforts to assist an animal control officer capture the defendant’s dogs, who did not have their required rabies tags; it was unnecessary for the state to prove the underlying offense that caused the officers to act. Jarvis v. State, 294 Ga. App. 482, 669 S.E.2d 477 (2008). Evidence was sufficient when defendant physically resisted police. — There was sufficient evidence to support defendant’s conviction for obstructing an officer in violation of O.C.G.A. § 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. Lord v. State, 276 Ga. App. 209, 622 S.E.2d 887 (2005). Evidence that the defendant refused to get into a patrol car and struggled with two officers, then told the defendant’s spouse, ‘‘I will kill you when I get out of jail,’’ supported the defendant’s convictions of terroristic threats and obstructing or hindering a law enforcement officer under O.C.G.A. §§ 16-10-24(a) and Application (Cont’d) 16-11-37(a). For there to be a violation of O.C.G.A. § 16-11-37(a), a defendant did not have to have the immediate ability to carry out a threat. Reeves v. State, 288 Ga. App. 544, 654 S.E.2d 449 (2007). 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. Council v. State, 291 Ga. App. 516, 662 S.E.2d 291 (2008). Because defendant swung at a police officer’s face with a loose handcuff and violently struggled during an attempted arrest, the evidence was sufficient to sustain a felony obstruction conviction under O.C.G.A. § 16-10-24(b). Smith v. State, 294 Ga. App. 579, 669 S.E.2d 530 (2008). Evidence that a defendant gave a fake name and address, sped from the scene of a traffic stop, abandoned the truck, and continued to run from, hide from, and fight with police was more than sufficient to support convictions for misdemeanor obstruction of a police officer in violation of O.C.G.A. § 16-10-24(a) and fleeing or attempting to elude in violation of O.C.G.A. § 40-6-395(a). Lightsey v. State, 302 Ga. App. 294, 690 S.E.2d 675 (2010). Evidence was sufficient to convict a defendant of attempting to remove a firearm from a police officer in violation of O.C.G.A. § 16-10-33(a) and obstruction of an officer in violation of O.C.G.A. § 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. The defendant also kicked and flailed at the officers, preventing the officers from handcuffing the defendant. Daniel v. State, 303 Ga. App. 1, 692 S.E.2d 682 (2010). Acquittal of charge for which defendant was arrested did not invalidate conviction for felony obstruction. — 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. § 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. Lammerding v. State, 255 Ga. App. 606, 565 S.E.2d 908 (2002). Status of off-duty deputy working as security guard. — 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. Carr v. State, 176 Ga. App. 113, 335 S.E.2d 622 (1985). Status of off-duty police officer as security guard. — Defendant was guilty under O.C.G.A. § 16-10-24 for shooting a police officer who was ‘‘moonlighting’’ as a security guard and who intervened in a disturbance occurring on premises outside of the officer’s immediate employment area’s domain. Davis v. State, 263 Ga. 5, 426 S.E.2d 844, cert. denied, 510 U.S. 950, 114 S. Ct. 396, 126 L. Ed. 2d 344 (1993). Although an officer was working an off-duty job providing security for a store, the officer was in the lawful discharge of the officer’s official duties when the officer detained a defendant’s girlfriend for shoplifting and also for purposes of charging the defendant with misdemeanor obstruction after the defendant disobeyed the officer by removing the girlfriend’s car from the store parking lot. Stryker v. State, 297 Ga. App. 493, 677 S.E.2d 680 (2009). Legally authorized persons supervising juveniles. — Because a team leader and a program manager were authorized to supervise defendant juveniles at a school and manage a wilderness program, they were legally authorized persons protected by O.C.G.A. § 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. In the Interest of M. W., 296 Ga. App. 10, 673 S.E.2d 554 (2009). Acquittal for simple battery does not negate absence of elements of obstruction. — Acquittal on simple battery charge showed that jury was not convinced beyond a reasonable doubt that appellant intentionally made physical contact of an insulting or provoking nature with deputy or that appellant physically harmed the deputy intentionally, but did not show that the jury necessarily found that appellant did not obstruct or hinder the deputy in performing official duty. Duncan v. State, 163 Ga. App. 148, 294 S.E.2d 365 (1982). Simple battery is not a lesser included offense of felony obstruction, because it is a separate and independent offense wherein the intent is to make physical contact or cause physical harm. Pearson v. State, 224 Ga. App. 467, 480 S.E.2d 911 (1997). Proof of physical fighting not required. — Fact that the indictment used the word ‘‘fighting’’ did not require the state to prove the defendant physically fought with the officer; it was enough to show the defendant verbally threatened the officer and acted in opposition to the officer’s authority by wielding a tire iron. Jackson v. State, 213 Ga. App. 520, 444 S.E.2d 875 (1994). Verbal threats of force or violence can obstruct an officer and authorize a felony conviction under O.C.G.A. § 16-10-24. Pearson v. State, 224 Ga. App. 467, 480 S.E.2d 911 (1997). Proof of lawfulness of arrest. — 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. Green v. State, 240 Ga. App. 774, 525 S.E.2d 154 (1999). 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. Additionally, it was not necessary to introduce the city ordinance on disorderly conduct in order to convict. Thompson v. State, 259 Ga. App. 518, 577 S.E.2d 839 (2003). Evidence supported defendant’s obstruction of a law enforcement officer conviction because the officers were acting within the lawful discharge of their duties in arresting defendant for theft under either O.C.G.A. § 16-8-2 or O.C.G.A. § 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. Cole v. State, 273 Ga. App. 259, 614 S.E.2d 883 (2005). Summary judgment based on qualified immunity was properly denied in a 42 U.S.C. § 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. § 16-10-24(a), and there was no error in concluding that the deputy had a duty to intervene in an unlawful arrest. Lepone-Dempsey v. Carroll County Comm’Rs, 2005 U.S. App. LEXIS 28258 (11th Cir. Dec. 16, 2005) (Unpublished). Underlying offense need not be shown. — It is not necessary for the state to prove the underlying offense that causes the officers to act; it is only necessary to prove the elements of the obstrucApplication (Cont’d) tion statute, i.e., that the act constituting obstruction was knowing and willful, and that the officer was lawfully discharging his official duties. Whaley v. State, 175 Ga. App. 493, 333 S.E.2d 691 (1985). 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. Kight v. State, 181 Ga. App. 874, 354 S.E.2d 202 (1987). No merger of felony and misdemeanor counts. — Counts of felony obstruction of an officer and misdemeanor obstruction of an officer did not merge; with regard to the felony, the defendant struck and kicked one officer, and with regard to the misdemeanor, the defendant refused to comply with the commands of a second officer. Ojemuyiwa v. State, 285 Ga. App. 617, 647 S.E.2d 598 (2007). Sufficiency of accusation. — 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. Reed v. State, 205 Ga. App. 209, 422 S.E.2d 15, cert. denied, No. S92C1446, 1992 Ga. LEXIS 865 (1992). In an action in which the state charged that defendant violated O.C.G.A. § 40-6-395(a) by willfully failing or refusing to bring defendant’s vehicle to a stop or otherwise fled or attempted to elude a pursuing police officer when given a visual or audible signal to bring the vehicle to a stop, and the state charged that defendant violated O.C.G.A. § 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. Golden v. State, 276 Ga. App. 538, 623 S.E.2d 727 (2005). When resisting unlawful arrest constitutes defense. — 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. Williams v. State, 196 Ga. App. 154, 395 S.E.2d 399 (1990). Violation involving separate victims. — Upon conviction of defendant of three counts of misdemeanor obstruction of a law enforcement officer, since there were three separate victims, the trial court did not err in treating the counts as discrete offenses for sentencing. Denny v. State, 222 Ga. App. 674, 475 S.E.2d 698 (1996). Refusal to provide identification to officer. — Jury could find that refusal to provide identification to officer might hinder execution of duties. Hudson v. State, 135 Ga. App. 739, 218 S.E.2d 905 (1975); Bailey v. State, 190 Ga. App. 683, 379 S.E.2d 816 (1989). Since there was no evidence that defendant was unruly or threatened to breach the peace or even that the officer thought defendant was drunk, and defendant’s sole offense was to refuse to give the defendant’s name, there was no probable cause for arrest; the arrest was not lawful and defendant’s physical resistance did not hinder the officer in the lawful discharge of the officer’s official duties. Wagner v. State, 206 Ga. App. 180, 424 S.E.2d 861 (1992). After an officer stopped a vehicle on the reasonable suspicion that the vehicle was being driven without a proper tag, and possibly for investigation of drug possession, refusal of defendant to provide identification in such circumstances could be the basis for prosecution under O.C.G.A. § 16-10-24 and the argument that detaining defendant under threat of such prosecution tainted the searches was without merit. Clark v. State, 243 Ga. App. 362, 532 S.E.2d 481 (2000). Venue. — Because all evidence showed that obstruction offense occurred at the location of the stop and arrest in a particular city, but there was no evidence that the location was within Glynn County as charged, the state failed to prove beyond a reasonable doubt that venue for the offense was properly laid in Glynn County; accordingly, defendant’s conviction for misdemeanor obstruction of a law enforcement officer required reversal. Bell v. State, 291 Ga. App. 169, 661 S.E.2d 207 (2008). Attack on correctional officer. — Inmate’s obstruction of a correctional officer conviction was upheld on appeal, based on sufficient evidence describing how the officer was attacked and the extent of the officer’s injuries suffered at the hand of the inmate, and testimony from one of the officer’s responding to the altercation describing the altercation; hence, the evidence sufficiently supported the jury’s rejection of the inmate’s self-defense claim. Pugh v. State, 280 Ga. App. 137, 633 S.E.2d 439 (2006). Use of conviction for impeachment. — 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. § 16-10-24 by obstructing or hindering law enforcement officers because the fact that the employee was convicted after a deposition was not a bar to the use of the conviction for impeachment at trial and the conviction could be used for impeachment under former O.C.G.A. § 24-9-84.1(a)(1) (see now O.C.G.A. § 24-6-609) because the violation was a felony punishable by imprisonment for not less than one nor more than five years. Todd v. Byrd, 283 Ga. App. 37, 640 S.E.2d 652 (2006), overruled on other grounds, Ferrell v. Mikula, 295 Ga. App. 326, 672 S.E.2d. 7 (2008). Prior similar act admissible. — Admission of similar transaction evidence in a case charging the defendant with possession of cocaine with intent to distribute, O.C.G.A. § 16-13-30(b), and obstructing or hindering law enforcement officers, O.C.G.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. Cotton v. State, 297 Ga. App. 664, 678 S.E.2d 128 (2009). Evidence of defendant’s statements while resisting arrest admissible. — Defense counsel was not deficient for failing to object to an officer’s testimony that while violently resisting arrest, the defendant repeatedly screamed, ‘‘I’m not going back to jail,’’ as evidence of these statements demonstrated the defendant’s intent to commit the crimes of obstructing and hindering law enforcement officers, and were not rendered inadmissible merely because the statements incidentally put the defendant’s character at issue. Bubrick v. State, 293 Ga. App. 502, 667 S.E.2d 666 (2008). Sufficient evidence for conviction. — See Manus v. State, 180 Ga. App. 658, 350 S.E.2d 41 (1986); Salter v. State, 187 Ga. App. 178, 369 S.E.2d 798 (1988); Patterson v. State, 191 Ga. App. 359, 381 S.E.2d 754 (1989); Powell v. State, 192 Ga. App. 688, 385 S.E.2d 772 (1989); Gordon v. State, 199 Ga. App. 704, 406 S.E.2d 110 (1991); Holloway v. State, 201 Ga. App. 204, 410 S.E.2d 799 (1991); Hall v. State, 201 Ga. App. 328, 411 S.E.2d 274, cert. denied, 201 Ga. App. 903, 411 S.E.2d 274 (1991); Herren v. State, 201 Ga. App. 509, 411 S.E.2d 552 (1991); Hendrix v. State, 202 Ga. App. 54, 413 S.E.2d 232 (1991), overruled on other grounds, Duke v. State, 205 Ga. App. 689, 423 S.E.2d 427 (1992); Hardwick v. State, 210 Ga. App. 468, 436 S.E.2d 676 (1993); Onwuzuruoha v. State, 217 Ga. App. 645, 458 S.E.2d 675 (1995); Imperial v. State, 218 Ga. App. 440, 461 S.E.2d 596 (1995); Miller v. State, 218 Ga. App. 606, 462 S.E.2d 630 (1995); Strickland v. State, 221 Ga. App. 516, 471 S.E.2d 576 (1996); Harris v. State, 222 Ga. App. 83, 473 S.E.2d 245 (1996); Cunningham v. State, 222 Ga. App. 740, 475 S.E.2d 924 (1996); Reddin v. State, 223 Ga. App. 148, 476 S.E.2d 882 (1996); Burk v. State, 223 Ga. App. 530, 478 S.E.2d 416 (1996); Brown v. State, 224 Ga. App. 42, 479 S.E.2d 454 (1996); Nunn v. State, 224 Ga. App. 312, 480 S.E.2d 614 (1997); Pearson v. State, 224 Ga. App. 467, 480 S.E.2d 911 (1997); Miller v. State, 226 Ga. App. 133, 486 S.E.2d 368 (1997); Youhoing v. State, 226 Ga. App. 475, 487 S.E.2d 86 (1997); Veal v. State, 226 Ga. App. 897, 487 S.E.2d 696 (1997); In re Application (Cont’d) C.W., 227 Ga. App. 763, 490 S.E.2d 442 (1997); Basu v. State, 228 Ga. App. 591, 492 S.E.2d 329 (1997); Larkin v. State, 230 Ga. App. 129, 495 S.E.2d 605 (1998); Leckie v. State, 231 Ga. App. 760, 500 S.E.2d 627 (1998); Wilson v. State, 233 Ga. App. 688, 505 S.E.2d 774 (1998); Johnson v. State, 234 Ga. App. 218, 507 S.E.2d 13 (1998); Pinchon v. State, 237 Ga. App. 675, 516 S.E.2d 537 (1999); Nichols v. State, 238 Ga. App. 412, 519 S.E.2d 20 (1999); Richardson v. State, 239 Ga. App. 345, 521 S.E.2d 239 (1999); Russell v. State, 243 Ga. App. 378, 532 S.E.2d 137 (2000); Burge v. State, 243 Ga. App. 673, 534 S.E.2d 132 (2000); Wilder v. State, 243 Ga. App. 807, 534 S.E.2d 487 (2000); Patterson v. State, 244 Ga. App. 222, 535 S.E.2d 269 (2000); McLeod v. State, 245 Ga. App. 668, 538 S.E.2d 759 (2000); Shaw v. State, 247 Ga. App. 867, 545 S.E.2d 399 (2001); Brackins v. State, 249 Ga. App. 788, 549 S.E.2d 775 (2001); Evans v. State, 250 Ga. App. 70, 550 S.E.2d 118 (2001); Adams v. State, 263 Ga. App. 694, 589 S.E.2d 269 (2003); Bounds v. State, 264 Ga. App. 584, 591 S.E.2d 472 (2003); Hayes v. State, 281 Ga. App. 749, 637 S.E.2d 128 (2006). Defendant not justified in resisting arrest after failing to pay fine. — 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. Scott v. State, 227 Ga. App. 625, 490 S.E.2d 104 (1997). Kicking and biting officers sufficient. — Evidence that defendant purposefully kicked and attempted to bite officers as they were assisting in the investigation of a shooting was sufficient to support a conviction. Stepherson v. State, 225 Ga. App. 219, 483 S.E.2d 631 (1997). Differences in defendant’s and officer’s testimony for jury. — 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. Taylor v. State, 231 Ga. App. 73, 498 S.E.2d 552 (1998). Resisting arrest in drug transaction. — Construed most favorably to the verdict, the evidence that defendant sold cocaine to undercover officers was sufficient to allow a rational jury to find defendant guilty of selling a controlled substance, selling a controlled substance within 1,000 feet of a public housing project, and resisting arrest. Mikell v. State, 231 Ga. App. 85, 498 S.E.2d 531 (1998). 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. Chisholm v. State, 231 Ga. App. 835, 500 S.E.2d 14 (1998). Words as sufficient for conviction. — Evidence was sufficient to support a conviction since the defendant told a police officer that ‘‘if he saw [him] again, he was going to pop a cap in his ass,’’ which is street slang for shooting somebody. Arnold v. State, 249 Ga. App. 156, 545 S.E.2d 312 (2001). Kicking sufficient for 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. Gillison v. State, 254 Ga. App. 232, 561 S.E.2d 879 (2002). Throwing a bottle at officer. — Police officer’s testimony that defendant threw a bottle at the officer while the officer was trying to protect other officers who were arresting a violent suspect was sufficient evidence to support defendant’s conviction of obstruction of a law enforcement officer with violence in violation of O.C.G.A. § 16-10-24(b). Gibbs v. State, 255 Ga. App. 183, 564 S.E.2d 789 (2002). Obstruction of officer with vehicle. — Evidence was sufficient to support defendant’s conviction for felony obstruction of a police officer as it showed that the officer, who was assisting the officer’s brother in apprehending defendant after defendant was suspected of shoplifting, was in the lawful discharge of police duties, that defendant knew the officer was a police officer, and that defendant knowingly or willfully tried to injure the officer by driving defendant’s vehicle while the officer was hanging half-in and half-out of the vehicle. Frayall v. State, 259 Ga. App. 286, 576 S.E.2d 654 (2003). 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. § 16-10-24. Hamm v. State, 259 Ga. App. 412, 577 S.E.2d 85 (2003). Obstruction of jail detention officers. — Defendant’s convictions of obstruction of peace officers, 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. Williams v. State, 260 Ga. App. 286, 581 S.E.2d 313 (2003). Obstruction by giving false information. — 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. Wilson v. State, 261 Ga. App. 576, 583 S.E.2d 243 (2003). Defendant committed obstruction knowingly and willfully. — Evidence was sufficient to support defendant’s conviction for obstruction of a law enforcement officer, as the state proved defendant committed the obstruction act knowingly and willfully, and that the officer was lawfully discharging the officer’s duties at the time of the obstruction; the state was not also required to prove the underlying offense. Mai v. State, 259 Ga. App. 471, 577 S.E.2d 288 (2003). Evidence was legally sufficient to support the five convictions against defendant for obstruction of a law enforcement officer as it showed defendant twice obstructed officers by fleeing, twice obstructed officers by offering to do violence to their persons, and once obstructed an officer by doing violence to the officer, all while committing crimes during a six-week period. Brown v. State, 259 Ga. App. 819, 578 S.E.2d 516 (2003). Defendant obstructed an officer where defendant consented to the deputy’s entry into the home and defendant knowingly and willfully grabbed the deputy’s arm to stop the deputy from arresting another occupant of the dwelling. Schroeder v. State, 261 Ga. App. 879, 583 S.E.2d 922 (2003). Testimony from an eyewitness at the scene that the eyewitness heard suspicious noises in the adjacent government offices, which were closed for business for the day, then saw defendant flee from police while removing items from defendant’s pocket, when coupled with the discovery of 169 quarters which were found in the immediate vicinity of the tree where defendant was apprehended, the presence of tools at the crime scene, visible pry marks on the door which defendant attempted to open, and the destroyed gum ball machines, authorized the jury to infer that although defendant did not have the tools in defendant’s possession, defendant used them to break into the offices, steal the money from the destroyed machines, and attempt to flee the police and avoid apprehension; thus, defendant’s convictions for burglary, possession of tools for the commission of a crime, interference with government property, and obstruction of an officer were all affirmed. Harris v. State, 263 Ga. App. 866, 589 S.E.2d 631 (2003). Striking an officer sufficient for obstruction. — There was no evidence that the arresting officer assaulted defendant Application (Cont’d) first, but the appellate court concluded that the evidence was sufficient for a rational trier of fact to find defendant guilty beyond a reasonable doubt of obstruction of an officer by refusing to obey the officer’s lawful commands and by striking the officer in the face. Dudley v. State, 264 Ga. App. 845, 592 S.E.2d 489 (2003). Obstruction by a juvenile. — State’s evidence was sufficient to find juvenile defendant committed criminal trespass, obstructed a police officer, and interfered with government property, and the juvenile court properly adjudicated the juvenile delinquent; the juvenile threw an egg at an officer’s car damaging a plastic strip on the car window, broke at least two windows in the police substation, and obstructed an officer by fleeing after the officer was identified and ordered defendant to stop. In the Interest of M.M., 265 Ga. App. 381, 593 S.E.2d 919 (2004). After the defendant was lawfully arrested for attempted possession of cocaine, the defendant was not justified in obstructing the police and resisting arrest, and thus the evidence supported the defendant’s conviction for misdemeanor obstruction of justice under O.C.G.A. § 16-10-24(a). Massey v. State, 267 Ga. App. 482, 600 S.E.2d 437 (2004). Evidence sufficient for felony obstruction of officer. — Evidence was sufficient to support the defendant’s conviction for felony obstruction of an officer in violation of O.C.G.A. § 16-10-24(b) since the issue of whether the police officers provided inconsistent testimony was for the jury to decide, the defendant admitted that the defendant knew that the individual who defendant struck was a police officer, there was no requirement of proving actual injury as an element of the offense, and the officers were in lawful discharge of their duties at the time of the alleged obstruction because the officers had probable cause to arrest the defendant on a probation violation warrant; upon the officer approaching the defendant, the defendant fled and the defendant struggled, punched, and hit the officers as the officers tried to arrest the defendant. Phillips v. State, 267 Ga. App. 733, 601 S.E.2d 147 (2004). Evidence sufficient for misdemeanor obstruction. — 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. Cooper v. State, 270 Ga. App. 346, 606 S.E.2d 869 (2004), overruled on other grounds, Stryker v. State, 297 Ga. App. 493, 677 S.E.2d 680 (2009). 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. Wilson v. State, 270 Ga. App. 555, 607 S.E.2d 197 (2004). Sufficient evidence supported defendant’s conviction for misdemeanor obstruction of a police officer as the evidence showed that following the traffic stop of defendant’s vehicle, defendant, who was handcuffed, fled the scene, requiring that officers pursue and apprehend defendant. Kates v. State, 271 Ga. App. 326, 609 S.E.2d 710 (2005). Evidence supported defendant’s rape, aggravated sodomy, aggravated assault, criminal trespass, misdemeanor obstruction of a law enforcement officer, felony obstruction of a law enforcement officer, and possession of marijuana conviction because: (1) a victim testified that defendant choked her, slammed her around a room, and raped and sodomized her, then drank a beer, took her BC powder packets, and a cell phone, and left; (2) defendant fled from the police, kicked two officers, and had marijuana, BC packets, and a cell phone on his person; (3) defendant’s DNA matched the DNA on the beer can; (4) a nurse testified that the victim’s bruise was consistent with strangulation; and (5) a doctor testified that the victim’s injuries were consistent with rape and sodomy. Lewis v. State, 271 Ga. App. 744, 611 S.E.2d 80 (2005). 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. § 16-10-24(a); it was not an inconsistent verdict that the jury acquitted the defendant of felony obstruction charges under O.C.G.A. § 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. Jones v. State, 276 Ga. App. 66, 622 S.E.2d 425 (2005). Refusal to allow entrance into home sufficient. — Evidence supported defendant’s conviction of misdemeanor obstruction of a law enforcement officer because: (1) an officer went to a residence to perform a safety check after a 9-1-1 hang-up call was received from the residence; (2) comments made to the officer by a child trying to climb out of a front window led the officer to believe that a domestic violence incident might be in progress inside the residence; (3) the officer entered the home and saw defendant, who uttered profanities, walked toward the officer and ordered the officer out of the house, and the officer then stepped outside the house; (4) after another officer arrived, the officers told defendant that they needed to enter the house to investigate the call, but defendant refused to allow the officers into the house; and (5) eventually, the officers were required to arrest defendant to enter the house. Berrian v. State, 270 Ga. App. 582, 608 S.E.2d 540 (2004). Obstruction by failing to remain in vehicle. — 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. Turner v. State, 274 Ga. App. 731, 618 S.E.2d 607 (2005). Because the defendant acknowledged hunting doves in an open field without a hunting license and ‘‘fading’’ into the woods when the rangers approached, the rangers had a reasonable and articulable suspicion that illegal activity had occurred; consequently, the defendant’s Fourth Amendment rights against unreasonable search and seizure were not violated and the trial court properly denied the defendant’s motion for a new trial on the charges of illegal hunting and obstruction. Sharp v. State, 275 Ga. App. 487, 621 S.E.2d 508 (2005). Fighting with officer during arrest sufficient. — 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. Mayfield v. State, 276 Ga. App. 544, 623 S.E.2d 725 (2005). Intentional or accidental striking of officer. — 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 Application (Cont’d) found on the defendant’s person or stashed in bags outside the home. Smith v. State, 279 Ga. 172, 611 S.E.2d 1 (2005). Evidence indicating that while officers were attempting to arrest the defendant in a domestic dispute, the defendant, after intentionally striking the victim one last time, intentionally punched one of the officers and then, intentionally or accidentally, struck the other with an elbow, was sufficient to support convictions for felony obstruction of a law enforcement officer and simple battery. Pinkston v. State, 277 Ga. App. 432, 626 S.E.2d 626 (2006). Striking and kicking sufficient for conviction. — Evidence was sufficient to support the defendant’s O.C.G.A. § 16-10-24(b) conviction for felony obstruction of a police officer after the officer tried to arrest the defendant on an outstanding warrant and after the officer was identified and ordered defendant to stop, the defendant struck and kicked the police officer as the defendant attempted to flee. Panzner v. State, 273 Ga. App. 868, 616 S.E.2d 201 (2005). Defendant’s conviction for misdemeanor obstruction was supported by sufficient evidence which established that when an officer activated the patrol vehicle’s flashing blue lights, giving a visual signal for the defendant to remain stopped, the defendant fled from the scene and led the officers on a chase until defendant was apprehended and arrested. Prather v. State, 279 Ga. App. 873, 633 S.E.2d 46 (2006). Obstruction of prison guards. — 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. Griffin v. State, 281 Ga. App. 249, 635 S.E.2d 853 (2006). Given the evidence provided by law enforcement that: (1) the defendant hindered and obstructed one officer in the lawful discharge of that officer’s duties while the officer went to check on the welfare of the defendant’s wife; (2) the defendant’s act of resisting the other officer while that officer was arresting the defendant; and (3) the defendant’s act of breaking off the interior door handle of the patrol vehicle and forcing the vehicle’s window off the window’s frame, the defendant’s convictions for both felony and misdemeanor obstruction of an officer and a felony count of interfering with government property were upheld on appeal. Meeker v. State, 282 Ga. App. 77, 637 S.E.2d 806 (2006). Given evidence from an ensuing police officer identifying the defendant as the driver of the vehicle stopped, and because the jury was the judge of the credibility of the witnesses presented at trial, and was authorized to reject the defendant’s alibi defense, sufficient evidence was presented to support the defendant’s convictions for reckless driving, failure to maintain a lane, driving with defective equipment, fleeing or attempting to elude a police officer, and obstruction of a police officer. Daniel v. State, 282 Ga. App. 291, 638 S.E.2d 430 (2006). Despite the defendant’s challenge to the sufficiency of the evidence, specifically, that no evidence showed the malice element of a cruelty-to-children offense, and that the evidence failed to show the defendant harmed the police officer to support an obstruction offense, convictions on those offenses were upheld on appeal as: (1) the severity of the bite marks inflicted on the child victim allowed the court to infer malice; (2) actual harm to the officer was not an essential element of an obstruction charge; and (3) the defendant’s act of swinging at the officer’s face during an effort to resist arrest supported an obstruction. Sampson v. State, 283 Ga. App. 92, 640 S.E.2d 673 (2006). Spitting on officer sufficient. — Evidence supported the defendant’s conviction of obstructing or hindering a law enforcement officer by spitting on the officer; although the defendant denied spitting and argued that only two witnesses had testified otherwise, a fact could be established by one witness, and credibility was a jury matter. Dixon v. State, 285 Ga. App. 211, 645 S.E.2d 692 (2007). Evidence adduced at trial authorized any rational trier of fact to find the defendant guilty beyond a reasonable doubt of felony obstruction of law enforcement officers in violation of O.C.G.A. § 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. Andrews v. State, 307 Ga. App. 557, 705 S.E.2d 319 (2011). Testimony of the arresting officer that defendant attempted to spit on the arresting officer was sufficient to support a charge of misdemeanor obstruction. Williams v. State, 307 Ga. App. 675, 705 S.E.2d 906 (2011). Obstruction of prison guards. — When a deputy testified that the defendant resisted the deputy’s efforts to break up a prison fight, then turned on the deputy, punched the deputy, and swung at the deputy repeatedly, injuring the deputy, there was sufficient evidence of mutiny in a penal institution and felony obstruction of an officer; the trial court was authorized under O.C.G.A. § 16-2-6 to infer from the circumstances that the defendant both knowingly and willfully obstructed the deputy by the use of violence and intended to cause the deputy serious bodily injury by striking the deputy with a fist, and under former O.C.G.A. § 24-4-8 (see now O.C.G.A. § 24-14-8), it could rely solely on the deputy’s account of the events. Butler v. State, 284 Ga. App. 802, 644 S.E.2d 898 (2007). Because sufficient evidence was presented that the defendant physically assaulted an off-duty sheriff ’s officer prior to arrest and continued to resist and obstruct the officer’s official duties thereafter, the defendant was properly denied an acquittal and a new trial; moreover, given that the trial court properly charged the jury on the obstruction offense, explaining that a person committed the offense by knowingly and willfully obstructing or 16-10-24 hindering a law enforcement officer in the lawful discharge of that officer’s official duties, nothing beyond such was required. Helton v. State, 284 Ga. App. 777, 644 S.E.2d 896 (2007). 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. Jennings v. State, 285 Ga. App. 774, 648 S.E.2d 105 (2007), cert. denied, No. S07C1576, 2007 Ga. LEXIS 667 (Ga. 2007). Given evidence that the defendant attempted to forcefully resist being handcuffed and threatened the officers as the officers were exercising the officers’ lawful duties, that evidence was sufficient to find the defendant guilty of obstructing a law enforcement officer. Robinson v. State, 288 Ga. App. 219, 653 S.E.2d 810 (2007). Given the evidence of the defendant’s effort to resist law enforcement officers, which hindered the officers in carrying out the officers’ duties, the defendant’s misdemeanor obstruction of a law enforcement officer convictions were upheld on appeal as supported by sufficient evidence. Lipsey v. State, 287 Ga. App. 835, 652 S.E.2d 870 (2007). Because the testimony from the deputy named in the challenged count charging the defendant with felony obstruction testified that the defendant was making a scene, hollering, cussing, carrying on, kicking, screaming, resisting arrest, pulling away, and attempting to kick someone in the crowd, which was confirmed by the testimony of a second deputy, sufficient evidence was presented to support the felony obstruction charge. Owens v. State, 288 Ga. App. 771, 655 S.E.2d 244 (2007), cert. denied, 2008 Ga. LEXIS 274 (Ga. 2008). Providing false identification as obstruction. — Given evidence that the defendant: (1) knowingly provided the officer with a false name and date of birth; Application (Cont’d) (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. Moreover, the trial court properly excluded a letter that the defendant claimed explained or justified the aforementioned actions as irrelevant. Williams v. State, 289 Ga. App. 402, 657 S.E.2d 556 (2008). Because direct eyewitness testimony from three eyewitnesses supported a finding that defendant struck a correctional officer while that officer was attempting to handcuff defendant, this evidence was sufficient to sustain defendant’s conviction of felony obstruction of an officer. Evans v. State, 290 Ga. App. 746, 660 S.E.2d 841 (2008). Sufficient evidence supported convictions of aggravated assault, aggravated assault on a peace officer, obstruction of a law enforcement officer, interference with government property, and criminal trespass after the defendant admitted obstructing officers and damaging a patrol car and the victim’s vehicle; although the defendant denied assaulting the victim and the responding officer, the jury was authorized to reject the defendant’s testimony. Gartrell v. State, 291 Ga. App. 21, 660 S.E.2d 886 (2008). Providing false identification as obstruction. — Evidence was sufficient to sustain the defendant’s conviction for giving false identifying information to and obstruction of law enforcement officers engaged in the lawful discharge of their official duties, O.C.G.A. §§ 16-10-24 and