In Stokes v. Territory, 14 Ariz. 242, 247-48, 127 P. 742, 744-45 (1912) the Arizona Supreme Court addressed a jury instruction on resisting arrest, given prior to statehood, for error. Specifically, the challenged instruction, which was subsequently affirmed, charged the jury: If you find, under the instructions given, that Woods was a peace officer, lawfully endeavoring to arrest, or had lawfully arrested, Stokes, and that Stokes was willfully resisting such arrest, knowing Woods to be an officer, then I charge you, as a matter of law, that such resistance was a felony. Id. at 248, 127 P. at 744.