In People v. Dolan, 172 AD2d 68, 576 N.Y.S.2d 901 (3rd Dept 1991), appeal denied, 79 N.Y.2d 946, 592 N.E.2d 808, 583 N.Y.S.2d 200 (1992), defendant was charged with obstructing governmental administration in the second degree, which involved the intentional disruption of controlled drug purchases.

Defendant had personally appeared at the scene of an undercover drug purchase in progress in uniform.

Additionally, defendant dispatched two marked police cars containing officers to the same scene.

The Court disagreed with defendant's contention that he had not obstructed governmental administration since there was no proof that he sent the marked police cars or he used intimidation or physical force. Notwithstanding defendant's argument, the Appellate Division held that:

"Physical force or (physical) interference (Penal Law § 195.05) can consist of inappropriate and disruptive conduct at the scene of the performance of an official function (see, People v. Case, 42 NY2d 98, 102, 365 N.E.2d 872, 396 N.Y.S.2d 841). The arrival of the two police cars which had not been sent to the scene by the dispatcher, coinciding with defendant's personal arrival, sufficiently linked him to disruptive conduct. These acts constituted a knowing, physical interference and disruption with an undercover police operation. Viewing the evidence in a light most favorable to the prosecution, a rational trier of fact could have found that defendant's guilt had been proven beyond a reasonable doubt ." (Id. at 75.)