Obstructing The Administration of Law (Part 2)

The Supreme Court continued: Questions of statutory interpretation are legal ones. Our review of a trial court’s legal conclusions is de novo and “unconstrained by deference to the decisions of the trial court or the appellate panel.”

Principles of statutory construction guide our analysis. Our primary goal in interpreting a statute is to determine to the best of our abilities “the intent of the Legislature, and to give effect to that intent.” We start with the statute’s plain language, giving terms their ordinary meaning. If the plain language of a statute is clear, that ends the matter; we then are duty-bound to apply that plain meaning.

A person violates N.J.S.A. 2C:29-1(a) if he [or she] purposely obstructs, impairs or perverts the administration of law or other governmental function or prevents or attempts to prevent a public servant from lawfully performing an official function by means of flight, intimidation, force, violence, or physical interference or obstacle, or by means of any independently unlawful act. This section does not apply to failure to perform a legal duty other than an official duty, or any other means of avoiding compliance with law without affirmative interference with governmental functions.

The statute qualifies what conduct is prohibited — including obstruction of the administration of law — by reference to how the activity is carried out — including by means of “physical interference or obstacle.” By the plain and ordinary meaning of the terms of the statute, criminal liability for obstruction stems only from certain modes of behavior.

To violate N.J.S.A. 2C:29-1(a), a person must not only “purposely obstruct, impair or pervert the administration of law” but must do so through one of the specifically enumerated acts in the statute, through “physical interference or obstacle,” or through an “independently unlawful act.” In its second sentence, the statute specifically distinguishes the above behaviors from failures to perform non-official duties and other conduct.

The prosecution likely relied upon state and/or local ordinances requiring people to obey the directions of a police officer. Thus, the argument would be that failing to unlock the door under the circumstances of this case would be “an independently unlawful act.”