In Williams v. State, 285 Ga. App. 190 (1) (645 SE2d 676) (2007) the Court reversed the defendant's conviction of obstructing a law enforcement officer, where the defendant had stopped his vehicle and fled the scene after an officer in a marked patrol vehicle had begun following him. The Court recognized that flight from a police officer can constitute obstruction, but found the evidence insufficient there, because the officer had never activated his emergency lights or siren, or attempted to stop the defendant, or ordered him to stop once he began running.