People v. Case

In People v. Case (42 NY2d 98 [1977]) the defendant was charged with obstructing governmental administration for alerting another motorist via a CB radio that there was a radar speed checkpoint up ahead. The Court of Appeals, focusing on the language of the statute that proscribes only obstruction " 'by means of physical force or interference or by means of some independently unlawful act,' " held that "physical" modifies both "force" and "interference," and that "mere words alone do not constitute 'physical force or interference' such as to support the charge of obstructing governmental administration." (Supra, at 101-102.)