The following excerpt is from Mackinney v. Nielsen, 69 F.3d 1002 (9th Cir. 1995):
Mackinney's gesture of underlining the last part of his message did not "obstruct" the officers. In People v. Quiroga, 16 Cal.App.4th 961, 964, 20 Cal.Rptr.2d 446 (1993), review denied, Sept. 30, 1993, the police, responding to complaints of a noisy party, found the defendant in an apartment with several other people. When the defendant stood up from the couch, an officer ordered him to sit back down. The defendant did not comply immediately. He argued with the officer, refusing to sit down. Finally, according to the officer, he sat down again. Soon after, the officer ordered the defendant, who was allegedly reaching into the cushions of the couch, to keep his hands on his lap. Again the defendant initially refused to cooperate. When the officer later ordered the defendant to stand up, he refused "several times" until the officer pulled on his arm. Id.
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