Andrea Rochelle Fripp-Hayes v. Commonwealth of Virginia, 1500154

Appellant Andrea Fripp-Hayes was convicted by a jury of misdemeanor obstruction of justice (Va. Code § 18.2-460) after a traffic/stop incident and acquitted of felony assault on a police officer. The trial court imposed a $2,500 fine.
Officer Hristo Hristov was investigating a purse larceny captured on video and stopped a juvenile (K.F.) who matched the suspect’s description and hat; he asked for identification and to photograph K.F. for the investigation.
K.F. refused to be photographed without his mother present; Fripp-Hayes (his mother) arrived, told K.F. to get in her car, and refused the officer’s repeated requests to provide her identification or allow her son to be photographed.
Officer Hristov ordered her not to leave; she drove off, the officer ran alongside and opened her door, she swerved and the officer’s foot was run over. Backup blocked her car and she was arrested; Hristov was treated at a hospital and released.
At trial Fripp-Hayes disputed key details (timing of requests, whether she swerved or ran over the officer’s foot) and argued mere refusal to identify herself did not constitute obstruction; the jury found her guilty of obstruction and the appellate court reviewed sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove obstruction of justice under Va. Code § 18.2-460	Commonwealth: appellant prevented officer from performing duties (prevented photographing juvenile) and acted with intent to obstruct	Fripp-Hayes: mere refusal to identify is not obstruction; contact resulted from officer chasing car, not purposeful act to obstruct; officer ultimately photographed K.F. so investigation was not prevented	Affirmed: evidence sufficient — her repeated refusal, attempt to drive away with son, and running over the officer’s foot precluded the officer from performing his duty and supported an inference of intent to obstruct

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review in criminal cases)
Jones v. Commonwealth, 141 Va. 471 (1925) (obstruction requires acts showing intent to prevent officer from performing duty)
Thorne v. Commonwealth, 66 Va. App. 248 (refusal to comply with repeated officer requests that completely prevent performance can support obstruction conviction)
Molinet v. Commonwealth, 65 Va. App. 572 (two-step analysis: (1) did acts prevent performance; (2) was there intent to obstruct)
Coles v. Commonwealth, 270 Va. 585 (intent may be inferred from circumstantial evidence and voluntary acts)