People v. Kotlinski 

Defendant was convicted, after jury trial, of obstructing a peace officer. State failed to prove Defendant guilty beyond a reasonable doubt. Officers stopped vehicle at 3 a.m. on New Year's Day because five people were in car. Defendant was front-seat passenger in vehicle driven by his wife who was asked to perform field sobriety tests after officers detected odor of alcohol in car. Defendant had stepped outside of car, which was not an act of obstruction, because officer never told Defendant he had to stay inside the car, but only a brief 21-second interruption of officer's duties. Defendant delayed only 47 seconds, per video, in getting back in car after officer told him to do so, and video contradicted officers' testimony as to course of events. (McLAREN and BOWMAN, concurring.)