Beckom v. State

In Beckom v. State, 286 Ga. App. 38 (648 SE2d 656) (2007), the police knocked on the defendant's door to inquire about the whereabouts of a missing juvenile. Beckom finally responded after approximately an hour and told the officers that she did not know the location of the juvenile. She called his name, however, and he emerged from her basement and was reunited with his father. After the police left, they returned to Beckom's and knocked on her door repeatedly, but she refused to answer. Beckom did not provide false information to the authorities, and "there was no evidence that she knew of an on-going investigation, and certainly no evidence that she was attempting 'knowingly and willfully' to impede such an investigation." Id. at 42 (2). The defendant initially refused to respond when the police repeatedly knocked on her door and called her home phone. See Beckom, 286 Ga. App. at 42 (2). When the defendant finally opened the door, she was verbally abusive. The Court concluded that her actions did not constitute obstruction because there was no evidence that she knew that there was an on-going police investigation or that she attempted to wilfully impede such an investigation. See id. Thus, the Court concluded that the evidence did not support her obstruction conviction.