Uzoukwu v. Krawiecki, No. 13-3483 (2d Cir. 2015)
Annotate this CaseDefendant appealed the dismissal of his claims for false arrest and excessive force under 42 U.S.C. 1983. Halfway through deliberations, the jury sent a note asking whether “refusal to acknowledge/respond to police questions [is] considered obstruction of governmental administration.” The district court equivocally answered that “[r]efusal to answer police questions alone, without more, would not constitute obstruction of governmental administration,” but that such a determination would “depend[] on the totality of the circumstances as you find them.” However, New York law unambiguously holds that one cannot obstruct governmental administration merely by refusing to answer police questions or to provide identification, both because such conduct is constitutionally protected, and because obstruction of governmental administration requires as an element a physical or independently unlawful act. The court vacated the verdict and remanded for a new trial because this prejudicial error was indisputably preserved.
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