In Fallon v. State, 221 P.3d 1016, 1021 (Alaska App. 2010) the Court upheld a resisting arrest conviction based on evidence that "Fallon ... struggled against Trooper Carson's efforts to arrest him. When Carson took Fallon to the back of the patrol car, Fallon pushed himself away from the car, so that Carson had to take him to the ground. With Fallon in that position, Carson still could not handcuff him, because Fallon tried to get up and continued to tense his arms against his back. Ultimately, it took the help of a passing motorist to get Fallon handcuffed and in the patrol car." The Court concluded that Fallon's conduct "went beyond 'mere non-submission,'" and we upheld Fallon's conviction for resisting arrest by force.