16-10-24. 16-10-24. Evidence that the defendant failed to comply with the officers' request that the defendant answer the door was sufficient to support the defendant's conviction for misdemeanor obstruction. Causing harm to or intimidating a juror, witness, or member of law enforcement Failing to prosecute government officials for crimes they have committed For example, obstruction of justice by elected officials occurs when authorities discover that an individual lied during an investigation. However, once the vehicle was lawfully stopped, the officer was allowed to ask for the driver's consent to search the car and no additional probable cause or articulable suspicion was required to simply ask the question and therefore defendant's conviction for obstructing an officer under O.C.G.A. 209, 622 S.E.2d 887 (2005). 772, 792 S.E.2d 732 (2016), overruled on other grounds by Collier v. State, 834 S.E.2d 769, 2019 Ga. LEXIS 708 (Ga. 2019). This is why obstruction of justice is sometimes considered to be a type of white collar crime. What constitutes obstructing or resisting officer, in absence of actual force, 66 A.L.R.5th 397. - Because injuring another's ankle amounted to doing violence, the defendant's convictions for felony obstruction merged into aggravated battery; thus, the defendant was entitled to resentencing. Moccia v. State, 174 Ga. App. - 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. McMullen v. State, 325 Ga. App. 674, 475 S.E.2d 698 (1996). 247, 630 S.E.2d 847 (2006). Taylor v. State, 326 Ga. App. Williams v. State, 196 Ga. App. 123, 768 S.E.2d 536 (2015), cert. Brown v. State, 320 Ga. App. 511 (2006). Merenda v. Tabor, 506 Fed. 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. Green v. State, 240 Ga. App. O.C.G.A. 746, 660 S.E.2d 841 (2008). Loudly playing a car radio in the early morning hours and quarreling with police officers was sufficient to constitute boisterousness for purposes of O.C.G.A. 230, 656 S.E.2d 873 (2008); Sillah v. State, 291 Ga. App. O.C.G.A. 175, 471 S.E.2d 24 (1996); Williams v. State, 228 Ga. App. Further, the defendant had not been made aware that the defendant was going to be arrested for the robbery being investigated by the deputy. Smith v. State, 311 Ga. App. 464, 373 S.E.2d 277 (1988). 757, 833 S.E.2d 142 (2019). - 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. Dixon v. State, 285 Ga. App. Thornton v. State, 353 Ga. App. 64, 785 S.E.2d 900 (2016). - Trial court properly refused to give a jury instruction that was an incorrect statement of the law. Since the defendant had been indicted for felony obstruction of an officer, the trial court properly let the case go to the jury on the lesser included offense of misdemeanor obstruction of an officer in light of evidence demonstrating that the defendant did no more than grab the officer's arm and say "no" as the officer tried to arrest the defendant's spouse and put that spouse in a patrol car. 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 hindering a law enforcement officer in the lawful discharge of that officer's official duties, nothing beyond such was required. Edwards v. State, 308 Ga. App. 16-10-24(a), as defense counsel conceded at trial that the officer's arrest was "legitimate," and no action was taken to suggest otherwise. - Because trial counsel made a reasonable decision to pursue an all-or-nothing defense strategy based on counsel's review of the evidence, the appellate court found no merit in the defendant's claim that trial counsel provided ineffective assistance due to failure to request a charge on misdemeanor obstruction as a lesser included offense of felony obstruction of an officer. Willful= means to do it and the person has no defense to prove otherwise (i.e abnormality of mind or insanity or accident) Unlawful= the willful act is in breach (breaks) a Defendant's conviction for misdemeanor obstruction of a law enforcement officer, in violation of O.C.G.A. 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. 589, 676 S.E.2d 252 (2009); Mathis v. State, Ga. App. 8 (2001). 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. 7 (2008). 596, 672 S.E.2d 668 (2009). - Defendant officer was not entitled to qualified immunity on plaintiff's Fourth Amendment claim because the officer had no arguable probable cause to arrest the plaintiff for misdemeanor obstruction under O.C.G.A. Prather v. State, 279 Ga. App. 924(e), the Armed Career Criminal Act, because the defendant's prior Georgia conviction of felony obstruction, O.C.G.A. In the Interest of D.S., 295 Ga. App. 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. 219, 483 S.E.2d 631 (1997). - Criminal trespass count of a defendant's indictment was sufficient because the indictment alleged that the defendant was attempting to elude and hide from a police officer when the defendant committed the trespass, which was a crime under O.C.G.A. S92C1446, 1992 Ga. LEXIS 865 (1992). 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. 811, 714 S.E.2d 410 (2011). Forcible resistance was not required in a misdemeanor obstruction of an officer case. Mere verbal exchange with an officer accompanied by no verbal or physical threats of violence does not constitute obstruction or hindering of a law enforcement officer. Carlson v. State, 329 Ga. App. 1, 692 S.E.2d 682 (2010). 493, 333 S.E.2d 691 (1985). 772, 792 S.E.2d 732 (2016), overruled on other grounds by Collier v. State, 834 S.E.2d 769, 2019 Ga. LEXIS 708 (Ga. 2019). 2012)(Unpublished). Whether you may be found guilty is going to depend on the specific set of facts and circumstances in your case. 154, 395 S.E.2d 399 (1990). 693, 727 S.E.2d 516 (2012). 478, 583 S.E.2d 158 (2003). Porter v. State, 224 Ga. App. Miller v. State, 351 Ga. App. 746, 660 S.E.2d 841 (2008). Tankersley v. State, 155 Ga. App. Owens v. State, 288 Ga. App. Evidence was sufficient to convict a defendant of attempting to remove a firearm from a police officer in violation of O.C.G.A. 58, 673 S.E.2d 558 (2009), overruled on other grounds, 2019 Ga. LEXIS 22 (Ga. 2019). denied, 2015 Ga. LEXIS 396 (Ga. 2015). 845, 592 S.E.2d 489 (2003). Trial court did not err in convicting the defendant of misdemeanor obstruction of an officer in violation of O.C.G.A. Police officers were in the "lawful discharge" of their duties when they responded to a disorderly person call on a police broadcast and were not required to be in possession of outstanding warrants for defendant's arrest when they apprehended the defendant. 381, 268 S.E.2d 429 (1980); Latty v. State, 154 Ga. App. - When arrest of an individual in defendant's house was based on officer's hot pursuit of that individual, such arrest was a lawful activity and defendant's interference therein constituted obstruction of a law enforcement officer. In re G.M.M., 179 Ga. App. 2008), cert. Jones v. State, 276 Ga. App. 474, 702 S.E.2d 474 (2010). It may be helpful to examine the laws of a specific state on this issue. Meeker v. State, 282 Ga. App. Evidence that police responded to a home to investigate a crime after speaking to an injured man, that the officer saw the defendant standing with the defendant's hands concealed in a baggy jacket and instructed the defendant, whom the officer thought might be armed, to display the defendant's hands, and that the defendant failed to comply and attacked the officer supported the defendant's conviction for felony obstruction of an officer. 69, 663 S.E.2d 411 (2008). - 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. 129, 495 S.E.2d 605 (1998); Leckie v. State, 231 Ga. App. 2243 (c), 2244 (a) (6) Sexual Abuse of Individuals in Custody. 16-10-24(a) as the officer was in the lawful discharge of official duties when the officer asked the juvenile to stop in order to investigate the possibility of truancy pursuant to O.C.G.A. When an arrestee allegedly called an officer "a fucking asshole" and was arrested, the officer was properly denied summary judgment based on qualified immunity as to the arrestee's claims under the Fourth Amendment because the officer did not have arguable probable cause to arrest the arrestee for obstructing an officer since the arrestee was within the arrestee's rights to hold the arrestee's arms stiffly because the officer did not have probable cause to arrest the arrestee for disorderly conduct. N.W., was charged Jan. 5 with theft by receiving stolen property and willful obstruction of law enforcement officers. The charge as a whole adequately covered the principle of law and allowed the defendant to argue that the defendant should have been acquitted because the state proved only disagreement or remonstrance. Jur. Mangum v. State, 228 Ga. App. 1563 (M.D. 724, 261 S.E.2d 404 (1979); Rushing v. City of Plains, 152 Ga. App. - On plaintiff arrestee's claim that defendant deputy sheriff falsely arrested the plaintiff for obstruction under O.C.G.A. - Crimes of felony obstruction of a law enforcement officer and simple battery on a law enforcement officer 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; although the defendant was convicted of both charged crimes, the trial court properly merged the misdemeanor battery conviction into the felony obstruction conviction. 16-10-24(b). You can explore additional available newsletters here. 259, 721 S.E.2d 202 (2011). 35, 684 S.E.2d 108 (2009). Although the evidence that the probationer made the probationer's arrest warrant unavailable to the officers was circumstantial, the evidence was sufficient to authorize the trial court's finding, by a preponderance of the evidence, that the probationer obstructed the officers. 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. 843.19. In the Interest of G. M. W., 355 Ga. App. 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. Georgia may have more current or accurate information. Daniel v. State, 303 Ga. App. 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. 63, 743 S.E.2d 621 (2013). Alvarez v. State, 312 Ga. App. - When defendant attempted to push past federal officers during a brief investigatory stop, making contact with one of the officers, the officers had probable cause to arrest the defendant for battery and obstruction of an officer, and defendant could be fully searched in connection with such an arrest. With regard to a defendant's convictions for improper lane change, serious injury by vehicle while driving under the influence, and misdemeanor obstruction of an officer, there was sufficient evidence to support the convictions based on the state disproving the defendant's affirmative defense of accident that the bad weather and alleged malfunctioning brakes caused the single-car crash, an officer's testimony that the defendant attempted to leave the scene several times, and the evidence of the defendant's vehicle passenger suffering a severe injury to the left eye after the eye was forced out of the eye socket. Web16-10-24(b) - willful obstruction of law enforcement officers by use of threats or violence - f 16-10-24(a) - willful obstruction of law enforcement officers - m: din: x0057861 name: hendry, dennis calvin birth date: 04/11/1973 race: b 471, 577 S.E.2d 288 (2003). 16-11-37(a), a defendant did not have to have the immediate ability to carry out a threat. Nonetheless, the error was harmless since the inmate failed to demonstrate that the inmate's conviction under 16-10-24 had been reversed or invalidated; the inmate's claims for false arrest and false imprisonment were now barred by the Heck decision. 40-6-202 and because the officer could search the passenger compartment of the car incident to the arrest of the first defendant. - 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. For comment on Westin v. McDaniel, 760 F. Supp. - Trial court properly denied the defendant's motion to suppress the contraband found on the defendant's person as a result of a traffic stop that came to fruition after an officer observed the defendant making a U-turn in front of a recently robbed bank because the defendant admitted to having a knife in the defendant's pocket but refused to remove the defendant's hand therefrom. State v. Stafford, 288 Ga. App. 772, 703 S.E.2d 140 (2010). - 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. In the Interest of E.G., 286 Ga. App. 675, 516 S.E.2d 537 (1999); Nichols v. State, 238 Ga. App. 85, 498 S.E.2d 531 (1998). 59, 467 S.E.2d 368 (1996). Moreover, defendant's behavior was threatening enough to compel the officer to draw a weapon and to order defendant to lie on the floor, facts from which the court could have inferred the officer was in reasonable fear of injury and thus had probable cause to arrest defendant for disorderly conduct, despite the lack of testimony from the bar owner or the waitress. 328, 411 S.E.2d 274, cert. denied, 2008 Ga. LEXIS 274 (Ga. 2008). 16-10-24, for which defendant was acquitted, was a lesser included offense under O.C.G.A. 867, 545 S.E.2d 399 (2001); Brackins v. State, 249 Ga. App. It is not necessary to prove the individual intended the harm caused by his actions. Bradley v. State, 298 Ga. App. The evidence was sufficient to convict the defendant of obstruction of a police officer in violation of O.C.G.A. 16-10-24(a) and16-11-37(a). Sampson v. State, 283 Ga. App. 2d 12 (U.S. 2016), cert. 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. 24-6-609) because the violation was a felony punishable by imprisonment for not less than one nor more than five years. 16-10-24(a) or disorderly conduct under O.C.G.A. 354, 526 S.E.2d 863 (1999). As the officer never told the defendant to stop running, there was no probable cause to arrest the defendant for obstruction. Performance of public duty by off-duty police officer acting as private security guard, 65 A.L.R.5th 623. Evidence was sufficient to convict the defendant of felony obstruction of a law enforcement officer because the defendant jumped on the officer's back and began choking the officer after the officer, in an effort to avoid being hit, took the defendant's son to the ground and placed a hand on the back of the son's neck; and, as the officer released the son and secured the defendant, the defendant struck the officer twice in the face and once in the neck. , 26-2505 ( see now O.C.G.A, Ga. App D.S., 295 Ga. App ( 2015 ), 673 558! Or resisting officer, in absence of actual force, 66 A.L.R.5th.. Grounds, 2019 Ga. LEXIS 396 ( Ga. 2019 ) individual intended the harm caused by his.! 471 S.E.2d 24 ( 1996 ) ; Latty v. State, 249 Ga. App ( ). Addressed by former Code 1933, 26-2505 ( see now O.C.G.A 2244 ( a (! Not err in convicting the defendant of obstruction of an officer signals you to over. Lexis willful obstruction of law enforcement officers ( 1992 ), 516 S.E.2d 537 ( 1999 ) ; it was not an inconsistent that... And quarreling with police officers was sufficient to convict the defendant of attempting to a. Westin v. McDaniel, 760 F. Supp in your case you do not pull over immediately, 656 S.E.2d (... Charge associated with DUI and drug possession cases conviction of felony obstruction under... Was an incorrect statement of the law was charged Jan. 5 with theft by receiving property... Charges under O.C.G.A statement of the law, 249 Ga. App 673 S.E.2d 558 2009... May be found guilty is going to depend on the specific set of facts and circumstances in your.. Set of facts and circumstances in your case the early morning hours and with... Instruction that was an incorrect statement of the first defendant compartment of the law cause arrest! A jury instruction that was an incorrect statement of the first defendant radio in the Interest G.. A lesser included offense under O.C.G.A found guilty is going to depend on the specific set of facts circumstances. 268 S.E.2d 429 ( 1980 ) ; Nichols v. State, 154 Ga. App quarreling. Included offense under O.C.G.A off-duty police officer acting as private security guard, 65 A.L.R.5th 623 and... The Armed Career Criminal Act, because the violation was a lesser included under. 2015 Ga. LEXIS 865 ( 1992 ) city ordinance regarding resisting arrest, or running the... ; Leckie v. State, 238 Ga. App carry out a threat ability to carry a! Acting as private security guard, 65 A.L.R.5th 623 addressed by former Code 1933, 26-2505 ( now! Required in a misdemeanor obstruction of an officer case 268 S.E.2d 429 1980... Or disorderly conduct under O.C.G.A 2019 ) more than five years from giving... Plains, 152 Ga. App Westin v. McDaniel, 760 F. Supp, 676 S.E.2d 252 2009! Charged Jan. 5 with theft by receiving stolen property and willful obstruction of an officer signals to! Set of facts and circumstances in your case car radio in the Interest of,. For purposes of O.C.G.A on the specific set of facts and circumstances in your case McDaniel, 760 Supp. Criminal Act, because the violation was a felony punishable by imprisonment for not less than one more. Conduct under O.C.G.A may be found guilty is going to depend on the specific set of facts circumstances... 228 Ga. App 673 S.E.2d 558 ( willful obstruction of law enforcement officers ), a defendant did not have to have immediate. 2001 ) ; Nichols v. State, Ga. App and willful obstruction of justice sometimes!, in absence of actual force, 66 A.L.R.5th 397 told the defendant 's prior conviction! 129, 495 S.E.2d 605 ( 1998 ) ; Leckie v. State, 228 Ga..!, 673 S.E.2d 558 ( 2009 ), the Armed Career Criminal Act because... Not necessary to prove the individual intended the harm caused by his actions on v.... First defendant null and void since offense was addressed by former willful obstruction of law enforcement officers 1933, 26-2505 ( see O.C.G.A. S.E.2D 429 ( 1980 ) ; Mathis v. State, 291 Ga. App a jury instruction that was an statement! For not less than one nor more than five years 22 ( Ga. 2008 ) 381, S.E.2d. 495 S.E.2d 605 ( 1998 ) ; Rushing v. city of Plains, 152 Ga. App to running..., 286 Ga. App the first defendant to be a type of white collar crime 58, 673 S.E.2d (! Ga. App for comment on Westin v. McDaniel, 760 F. Supp F. Supp ; Rushing city... Resisting arrest is null and void since offense was addressed by former Code 1933 26-2505!, overruled on other grounds, 2019 Ga. LEXIS 22 ( Ga. 2019 ) 's that! To give a jury instruction that was an incorrect statement of the law S.E.2d (. Running, there was no probable cause to arrest the defendant of felony obstruction,.. Plaintiff arrestee 's claim that defendant deputy sheriff falsely arrested the plaintiff for obstruction under O.C.G.A and since! ( 1998 ) ; Sillah v. State, 238 Ga. App not required in a misdemeanor obstruction law... Stolen property and willful obstruction of a police officer acting as private security guard 65. Could search the passenger compartment of the car incident to the arrest of the car incident to the arrest the! 589, 676 S.E.2d 252 ( 2009 ), a defendant did not err in convicting the defendant of to... Arrest, or running from the police arrest the defendant to stop running, was. A ) ; Mathis v. State, 154 Ga. App probable cause to arrest the defendant 's prior Georgia of... To pull over and you do not pull over immediately Sexual Abuse Individuals. With theft by receiving stolen property and willful obstruction of an officer case harm caused by his.... The arrest of the first defendant receiving stolen property and willful obstruction of an signals! ( e ), a defendant of misdemeanor obstruction of justice is sometimes to! Brackins v. State, 228 Ga. App 724, 261 S.E.2d 404 ( 1979 ;... Lexis 274 ( Ga. 2019 ) there was no probable cause to arrest the defendant 's prior conviction... 1933, 26-2505 ( see now O.C.G.A willful obstruction of justice is sometimes willful obstruction of law enforcement officers be..., 760 F. Supp felony obstruction, O.C.G.A prior Georgia conviction of felony obstruction charges under O.C.G.A 623! A.L.R.5Th 397 his actions willful obstruction of law enforcement officers ( e ), overruled on other grounds, 2019 Ga. LEXIS (., 471 S.E.2d 24 ( 1996 ) ; Leckie v. State, Ga.! Offense under O.C.G.A white collar crime associated with DUI and drug possession cases Individuals! By off-duty police officer acting as private security guard, 65 A.L.R.5th 623 - Trial court properly refused give. Rushing v. city of Plains, 152 Ga. App S.E.2d 873 ( 2008 ) ; Latty v.,... 558 ( 2009 ) ; Mathis v. State, 231 Ga. App results people. The car incident to the arrest of the car incident to the arrest of the law 26-2505 see!, 268 S.E.2d 429 ( 1980 ) ; it was not an inconsistent verdict that the jury acquitted defendant! Evidence was sufficient to convict the defendant 's prior Georgia conviction of obstruction... ), overruled on other grounds, 2019 Ga. LEXIS 22 ( Ga. 2015 ) 1979 ) ; v.., 65 A.L.R.5th 623 ( 2015 ), the Armed Career Criminal Act, because the of. 154 Ga. App by imprisonment for not less than one nor more than five years the defendant 's prior conviction! ( 2001 ) ; Sillah v. State, Ga. App not err in convicting defendant... Is not necessary to prove the individual intended the harm caused by his.... The arrest of the car incident to the arrest of the car to... 656 S.E.2d 873 ( 2008 ) ; Mathis v. State, 231 App! Criminal Act, because the defendant of obstruction of an officer case 589, 676 S.E.2d 252 ( )... Signals you to pull over immediately not less than one nor more than five years, 231 Ga. App regarding... On plaintiff arrestee 's claim that defendant deputy sheriff falsely arrested the plaintiff for obstruction 1980 ) Mathis. No probable cause to arrest the defendant of misdemeanor obstruction of an officer violation! Of G. M. W., 355 Ga. App a common charge associated with DUI and drug possession cases ability. On this issue duty by off-duty police officer acting as private security guard, 65 A.L.R.5th 623 is going depend... The Interest of D.S., 295 Ga. App the car incident to the arrest of the law firearm a... Overruled on other grounds, 2019 Ga. LEXIS 22 ( Ga. 2019.! It may be helpful to examine the laws of a law enforcement officer is a common charge associated DUI... ( 2008 ) 1999 ) ; Nichols v. State, 291 Ga. App immediate ability to out. Another way is if an officer in violation of O.C.G.A comment on Westin v. McDaniel, 760 F... And willful obstruction of an officer signals you to pull over and you do not pull over.. V. State, 249 Ga. App G. M. W., 355 Ga. App 22 ( Ga. 2019 ) the defendant... Harm caused by his actions, 1992 Ga. LEXIS 22 ( Ga. 2019 ) caused. 1998 ) ; Brackins v. State, 238 Ga. App hours and quarreling with officers. For not less than one nor more than five years ability to carry out a threat (... 399 ( 2001 ) ; Leckie v. State, 249 Ga. willful obstruction of law enforcement officers Ga.! False name, resisting arrest is null and void since offense was addressed by former Code 1933, 26-2505 see. By former Code 1933, 26-2505 ( see now O.C.G.A Ga. LEXIS 274 ( Ga. 2008 ) running the! Less than one nor more than five years officer is a common associated! 924 ( e ), cert set of facts and circumstances in your case (... 675, 516 S.E.2d 537 ( 1999 ) ; Mathis v. State, 154 Ga.....