Second Circuit
Thompson v. Clark, 14-CV-7349, 26 (E.D.N.Y. Jun. 26, 2018) (“If they were not lawfully able to enter the home, then plaintiff committed no crime by obstructing their path.”).
Eighth Circuit
Johnson v. City of Minneapolis, CV 08-359 (MJD/JJK), 2009 WL 10711599, at *6 (D. Minn. Aug. 24, 2009) (stating that “it was clearly established at the time of the incident that an individual cannot be arrested under Minn. Stat. § 609.50 unless that individual commits an intentional physical act of obstruction or interference, or uses words that have the same effect”).
Thompson v. City of Minneapolis, 06-CV-3131(JMR/FLN), 2008 WL 11458593, at *6 (D. Minn. Apr. 22, 2008) (“Because the Minnesota Supreme Court narrowed the criminal statute to require physical interference, the Court finds that a reasonable officer, confronted with plaintiffs’ version of the facts, would have understood there was no probable cause to arrest plaintiffs.”).
Walker v. City of Pine Bluff, 414 F.3d 989, 993 (8th Cir. 2005) (“But crediting Walker’s testimony, as we must, we have a case of a citizen who was arrested when he stood at a considerable distance from police officers engaged in a conversation with young men, who spoke only when spoken to, and who complied with Grace’s request for identification after pointing out that he had done nothing wrong. No reasonable police officer could believe that he had arguable probable cause to arrest such an on-looker in this situation, for obstruction of governmental operations or for any other purported crime.”).
Weiner v. Lappegard, CIV.04-630 RHK/JSM, 2005 WL 1155943, at *5 (D. Minn. May 16, 2005) (“The Court finds that genuine issues of material fact exist as to whether the officers possessed arguable probable cause to arrest Ms. Weiner for obstructing legal process. When viewed in a light most favorable to Ms. Weiner, the record shows that she merely approached the officers and asked them what they were doing at the residence and asked why they were using mace. Under this version of the facts, Ms. Weiner did not physically obstruct or interfere with the officers, nor did she use ‘fighting words’ or words that would have had the effect of physically obstructing or interfering with the officers.”) (footnote omitted).
Adewale v. Whalen, 21 F. Supp. 2d 1006, 1011 n.4 (D. Minn. 1998) (“Although citizens should be encouraged to assist officers whenever possible, a bystander is not under any legal obligation to open a door for a police officer performing an investigation without a warrant. Thus, plaintiff did not engage in illegal conduct when she refused to open the security door for Officers Whelan and Salter.”).
Arnott v. Mataya, 995 F.2d 121, 124 (8th Cir. 1993) (“Under the facts and circumstances of this case, a jury could reasonably believe that Arnott did not refuse to unlock the door, but hesitated to avoid being shot at through the door.”).