STATE OF NEW JERSEY VS. SANDRA NOLLEYÂ (A-34-15, CAMDEN COUNTY AND STATEWIDE), A-3984-15T1

Sandra Nolley was charged and convicted of obstruction of the administration of law, N.J.S.A. 2C:29-1, following an incident in an apartment on May 23, 2015.
Police responded to a call from Chris VanSciver asking officers to remove an "unwanted female."
Officer Olivieri entered the apartment, told Nolley Chris did not want her there, and asked her to leave and to provide identification.
Nolley refused to provide ID, cited the slogan "Hands up. Don't shoot," and refused to leave; she was arrested for obstruction.
Municipal court convicted Nolley; on de novo Law Division review the judge also convicted her but reduced the fine.
On appeal, this court reversed, holding the record did not show conduct meeting the statute's required means (flight, intimidation, force, violence, physical interference) or an independently unlawful act such as trespass.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nolley violated N.J.S.A. 2C:29-1 by refusing to leave or provide ID	Refusal to leave when ordered by police constitutes physical interference under the statute	Mere refusal to provide ID or leave (when seemingly lawfully on the premises) is not a crime and does not amount to obstruction	Reversed — conduct did not satisfy statute: no physical interference as defined, nor an independently unlawful act

Reece, 222 N.J. 154 (review standard — appellate deference to trial findings)
Powers, 448 N.J. Super. 69 (statute not to be loosely interpreted; must show statutory means)
Johnson, 42 N.J. 146 (appellate review principles)
Kuropchak, 221 N.J. 368 (scope of appellate review)
Barone, 147 N.J. 599 (deference to credibility findings)
Cerefice, 335 N.J. Super. 374 (deference to municipal credibility findings)
Mann, 203 N.J. 328 (no deference on pure legal questions)
Camillo, 382 N.J. Super. 113 (obstruction requires violent/physical interference or an independently unlawful act)
Hernandez, 338 N.J. Super. 317 (distinguishing refusal to leave during an arrest from refusal to leave otherwise)