In People v. Baker, 20 NY3d 354 (2013) the defendant yelled obscenities at a police officer on a public street, at which point, two officers placed him under arrest. Id. In concluding that the arrest for disorderly conduct was not based on probable cause, the Court of Appeals held that there was "no record basis" for finding the "public harm element." Id. at 362. There are other offenses in the Penal Law, such as menacing and harassment, that are intended to cover altercations of a personal nature. Id. at 360. But the "public harm" element of the disorderly conduct statute "performs an important narrowing function" that serves to distinguish it from those other offenses. Id.