State v. Lee

OPINION

BARKER, Judge.

¶ 1 The issue in this case is the amount of “physical force” that may constitute resisting arrest under Arizona Revised Statutes (“A.R.S.”) section 13-2508(A), and whether so-called “minor scuffling” may be sufficient in light of our construction of that statute and its legislative history. Finding that the conduct at issue here is sufficient to support a conviction, we affirm.

Facts and Procedural Backgroundl 1

¶ 2 On the evening of March 19, 2005, City of Phoenix Police Officers V, M, and S were attempting to arrest a man for an outstanding warrant outside an apartment…