How has section 69 of the California Criminal Code been interpreted in the context of a physical struggle between a defendant and an officer?

to fall "violently to the ground." (Id. at p. 520.) In addition, the defendant swung his hips from one side to the other attempting to free himself from the officer's grasp. (Ibid.) The court found this "forceful resistance" "amply supported [the defendant's] conviction of violating section 69." (Id. at pp. 518, 520.) Similarly, a physical struggle in which a defendant was kicking, struggling, and "squirm[ing]" satisfied section 69's element of "force or violence." (People v. Carrasco (2008) 163 Cal.App.4th 978, 985-986.)