Santos v. State

Ellington, Judge.

Following a bench trial, the Superior Court of DeKalb County found Jorge Santos guilty beyond a reasonable doubt of obstructing or hindering a law enforcement officer in the lawful discharge of his official duties, OCGA § 16-10-24 (a), for attempting to elbow the officer in the face, and battery, OCGA § 16-5-23.1, for wrestling with the officer and causing bruises to his shin and knee. On appeal, Santos contends that the allegedly criminal acts occurred during an illegal detention and that the trial court erred in denying his motion in limine to exclude all evidence that…