New York Court of Appeals
In the Matter of Davan L., a Person Alleged to Be a Juvenile Delinquent, Respondent
December 18, 199791 N.Y.2d 88
Summary
The Court held that the juvenile's conduct—circling the police operation, shouting warnings, and causing a dispersal—constituted obstruction of governmental administration under Penal Law § 195.05. Applying a de novo standard of review, the Court found the evidence sufficient to sustain the delinquency adjudication and reversed the Appellate Division's dismissal, remanding for further factfinding.