Defendant was convicted of disorderly conduct under a theory that he recklessly created a risk of public inconvenience, annoyance, or alarm by obstructing traffic (see Penal Law § 240.20 [5]). The People's proof demonstrated that even after an officer identified himself, defendant continued running from an unmarked police vehicle, zigzagging between the sidewalk and the street, and interfering with traffic.
Defendant's defense was that he was appropriately...
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