In People v. Santos (182 Misc 2d 764 [Crim Ct, NY County 1999]) after being arrested for a B misdemeanor, the defendant pulled away from the officer, sat in a chair and refused to get up when the officer attempted to fingerprint her (id. at 765). The court held that the defendant's actions constituted the use of physical force as well as interference with official government action (id. at 771).