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EXAMPLES OF RESISTING
Even seemingly minor actions by a suspect or arrestee can constitute ‘resistance’ within the meaning of Section 843.02. Common examples include:
Tensing arms while being handcuffed. M.J. v. State, 994 So. 2d 485 (Fla. 3d DCA 1985);
Not obeying lawful verbal commands;
Refusing to sit down. S.L. v. State, 96 So. 3d 1080, 1089 (Fla. 3d DCA 2012);
Refusing to be handcuffed or otherwise evading handcuffs. P.B. v. State, 899 So. 2d 480 (Fla. 3d DCA 2005);
Giving information deemed to be false or misleading during a lawful arrest or detention. Fripp v. State, 766 So. 2d 252, 254 (Fla. 4th DCA 2000);
Concealing evidence. Jean-Marie v. State, 947 So. 2d 484, 489 (Fla. 3d DCA 2007);
Refusing to leave an area when required. Wilkerson v. State, 556 So. 2d 453, 456 (Fla. 1st DCA 1990);
Evading police when there is reasonable suspicion of criminal wrongdoing. Williams v. State, 55 So. 3d 596 (Fla. 3d DCA 2011);
Interfering with active police investigation, or acting as a “look out” to prevent an intended arrest. Porter v. State, 582 So. 2d 41 (Fla. 4th DCA 1991).