People v. Sadder-Bey

Defendant appealed from his conviction for resisting a peace officer, arguing that his actions during a traffic stop were not enough to support his conviction, even though he did not obey the officer’s orders immediately. The appellate court agreed and reversed, concluding that the defendant’s acts must materially interfere with the officer and that defendant’s “quarrelsome” interaction with officers and his initial refusal to exit his vehicle when asked were “nothing more than token acts of resistance” that were not sufficient to support the conviction. (FITZGERALD SMITH and HOWSE, concurring)