Carlson v. the State, 329 Ga. App. 309

Carlson was convicted of felony obstruction of an officer, driving with a suspended license, and misdemeanor obstruction after a Cobb County police chase and struggle.
Evidence showed Carlson punched, kicked, grabbed handcuffs, and fought in arrest; officer used pepper spray and force to subdue him.
Trial court answered jury questions about elements of felony obstruction, allegedly conflating two elements.
Carlson argued the response plain-errors the trial court misdefined violence and resistance.
Trial court refused to charge misdemeanor obstruction as a lesser included offense because greater offense was proven.
Court affirmed Carlson’s convictions after reviewing plain-error standard and evidence sufficiency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plain error in jury instruction on felony obstruction elements	Carlson asserts error in defining violence and resistance	State contends no reversible plain error	No reversible plain error; unlikely to affect outcome
Failure to instruct on misdemeanor obstruction as lesser included offense	Carlson seeks lesser offense instruction	State argues greater offense proven	Not required; greater offense proven
Sufficiency of evidence for felony obstruction	Carlson contests sufficiency	State produced violent resistance evidence	Sufficient under Jackson v. Virginia

Jackson v. State, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for appellate sufficiency of evidence)
Norton v. State, 273 Ga. 332 (Ga. 2013) (plain-error framework and factors)
Gilliland v. State, 325 Ga. App. 854 (Ga. App. 2014) (plain error when lack of effect on verdict)
Hicks v. State, 287 Ga. 260 (Ga. 2010) (no plain error where unlikely to affect verdict)
Rouen v. State, 312 Ga. App. 8 (Ga. App. 2011) (overwhelming evidence negates error impact)
White v. State, 310 Ga. App. 386 (Ga. App. 2011) (lesser-included offense analysis when greater offense proven)
Williams v. State, 301 Ga. App. 731 (Ga. App. 2009) (standard for lesser included offenses)