Kendrick v. State, 324 Ga. App. 45

Kendrick appeals her misdemeanor obstruction conviction, challenging sufficiency of the evidence and the court's jury instruction.
Officer Mixon stopped Holmes for a defective brake light and tag light; he planned DUI investigation after smelling alcohol.
Kendrick arrived at the scene and ignored Mixon's orders to return to her car while the stop unfolded.
A struggle occurred when Mixon attempted to arrest Kendrick and a backup officer arrived; a video of the encounter was presented at trial.
The evidence was offered under OCGA § 16-10-24(a) that obstructing a law enforcement officer is a misdemeanor; the issue is whether the evidence proves every element beyond a reasonable doubt.
The court upheld the conviction, concluding the evidence was sufficient and the jury charge adequately covered the law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to prove obstruction	Kendrick argues evidence is insufficient	State contends evidence supports each element	Sufficient evidence supports conviction
Jury instruction adequacy	Kendrick seeks a charge requiring more than mere remonstrance	Charge covered the elements and law	Instruction adequately covered the law; no error

Jarvis v. State, 294 Ga. App. 482 (2008) (evidence sufficiency for obstructing an officer)
Turner v. State, 274 Ga. App. 731 (2005) (repeatedly ignoring officer's command supports obstruction)
Imperial v. State, 218 Ga. App. 440 (1995) (refusal to obey lawful command in crowded area supports obstruction)
Muhammad v. State, 243 Ga. 404 (1979) (mere presence without more is corollary to proving elements)
Gresham v. State, 303 Ga. App. 682 (2010) (when charge covers principles, failure to give a similar instruction is not error)
Stephens v. State, 214 Ga. App. 183 (1994) (substantially covered principles negate need for same specific instruction)