AT 2 & 11 order dated September 13, 2012, affirming judgment of conviction. Decision below: 36 Misc.3d 159A, 960 NYS2d 51, 2012 WL 4122023. Read, J., granted leave June 6, 2013.

ISSUE PRESENTED: The legal sufficiency of the misdemeanor complaint charging obstruction of governmental administration, where it alleged that defendant stood behind a police car and hit its trunk, without alleging that the police had told him that he had to move so that they could leave. (Assigned counsel: Steven Banks, Legal Aid Society, Criminal Appeal Bureau, 199 Water Street, NYC 10038.)

sufficiency of misdemeanor complaint charing obstruction of governmental administration