People v. Ravizee (1990)
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People v. Vargas (1998)
(Supra, at 681.) Reasoning that the concept of physical interference “has been construed to require neither the use by a defendant of direct physical force against the officer, nor even any direct physical contact between the two”, the Ravizee court held that the allegation that the defendant swallowed contraband to prevent or impede its recovery by the police “is, by itself, a punishable act of ‘physical interference’ under Penal Law § 195.05.” (People v Ravizee, supra, at …