What is the probable cause for a resisting arrest charge?

"New York", United States of America

The following excerpt is from People v. Brown, 2015 NY Slip Op 50046 (U) (N.Y. 2015):

3.The Bryan Court noted that defendant's conduct nevertheless provided probable cause for a Resisting Arrest charge. People v. Bryan, 190 Misc 2d at 823.

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