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People v. Case, 42 N.Y.2d 98, 365 N.E.2d 872, 396 N.Y.S.2d 841, 87 A.L.R.3d 77

Facts

The defendant was charged with obstructing governmental administration after he used a CB radio to inform other drivers about the location of a radar speed checkpoint while driving on State Route 37. The Town Justice Court convicted him of disorderly conduct as a lesser offense. The County Court affirmed this judgment, leading to the defendant's appeal to the Court of Appeals.

In an information sworn to by a State Police officer, defendant was charged with the commission of the crime of obstructing governmental administration, contrary to section 195.05 of the Penal Law, on December 19, 1975 in the Town of Oswegatchie, St. Lawrence County.

Issue

Does a citizen's band radio message from one motor vehicle operator to another regarding the location of a radar speed checkpoint constitute the crime of obstructing governmental administration?

A CB radio message from one motor vehicle operator to another as to the highway location of a radar speed checkpoint does not constitute the crime of obstructing governmental administration.

Rule

A person is guilty of obstructing governmental administration when he intentionally obstructs, impairs or perverts the administration of law or other governmental function by means of intimidation, physical force or interference, or by means of any independently unlawful act.

A person is guilty of obstructing governmental administration, under section 195.05 of the Penal Law 'when he intentionally obstructs, impairs or perverts the administration of law or other governmental function or prevents or attempts to prevent a public servant from performing an official function, by means of intimidation, physical force or interference, or by means of any independently unlawful act'.

Analysis

The court analyzed the statutory language of section 195.05 of the Penal Law, emphasizing that the term 'interference' must be understood in conjunction with its modifier 'physical.' The court concluded that mere words, such as a warning about a radar checkpoint, do not amount to physical interference as required by the statute. Therefore, the defendant's actions did not meet the legal definition of obstructing governmental administration.

The court must not be overly technical in interpreting penal provisions, penal responsibility cannot be extended beyond the fair scope of the statutory mandate.

Conclusion

The Court of Appeals reversed the order of the County Court, vacated the judgment of conviction, and dismissed the information against the defendant.

The order of the County Court of St. Lawrence County should be reversed, the judgment of conviction of the Town Justice Court of the Town of Oswegatchie should be vacated and set aside and the information against defendant should be dismissed.

Who won?

Defendant prevailed in the case because the court found that his warning about the radar checkpoint did not constitute a crime under the applicable statute.

The order reversed, judgment vacated and the information dismissed.

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