Washington v. Williams
Annotate this CasePetitioner Michael Williams drove away from a car dealership without paying for new tires and wheels. An employee called the police, and officers tracked down Petitioner at his girlfriend’s home. Petitioner admitted that he had driven away, but to avoid discovery of an outstanding warrant against him, Petitioner gave a fake name. Petitioner was convicted of first-degree theft, making false statements to an officer, and for obstructing law enforcement by giving a fake name. Petitioner appealed his obstruction conviction, arguing that legislative history and case law show that the trial court misinterpreted the applicable statute. The appellate court affirmed the conviction. The Supreme Court reversed the appellate court, holding that obstruction requires more than just a statement—it requires some conduct in addition to making the statement. The Court vacated Petitioner’s conviction on the obstruction charge alone, but affirmed the lower courts’ decisions in all other respects.
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