OPINION
BOSSON, Judge.
{1} Defendant appeals her conviction for battery upon a peace officer, NMSA 1978, § 30-22-24 (1971). Defendant contends her conviction should be reversed for four reasons: (1) the trial court refused to instruct the jury that her challenge to the officer's authority had to be "meaningful," pursuant to State v. Padilla, 1997-NMSC-022, ¶ 7,
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