People v. Galdamez CA3

DISCUSSION

I. Failure to Respond to Police Instructions Defendant contends there is no evidence that he committed an act “which delayed or obstructed the police investigation after the officers arrived on the scene.” Instead of delaying or obstructing, he did “nothing whatsoever” and “passively stayed seated behind a tree.” Defendant claims that cases interpreting Penal Code section 1481 “appear to require” that his actions or words occurred “after an actual encounter with a peace officer.” Citing People v. Quiroga (1993) 16 Cal.App.4th 961 (Quiroga), defendant argues that simple noncompliance with police orders is not criminalized. We reject defendant’s contention. “When a defendant challenges the sufficiency of the evidence, ‘ “[t]he court must review the whole record in the light most favorable to the judgment below to determine whether it discloses substantial evidence—that is, evidence which is reasonable, credible, and of solid value—such that a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt.” [Citation.]’ [Citations.] ‘Substantial evidence includes circumstantial evidence and any reasonable inferences drawn from that evidence.…