In re Manuel G.
Supreme Court of California
941 P.2d 880 (1997)
Sheriff's Deputy Sims was investigating a gang-related shooting and approached Manuel G. (defendant), a minor and known gang member, to ask about it. When Sims kept questioning him, Manuel repeatedly threatened to have Sims and other officers killed if they kept investigating the gang, continuing even after Sims warned him that threatening an officer was a crime. The juvenile court found Manuel violated Penal Code section 69, which criminalizes threatening an officer to deter lawful duties. The court of appeal reversed, reasoning that Sims had illegally detained Manuel before the threats began, so Sims wasn't engaged in lawful duty at that moment, meaning the threats couldn't count as illegal under the statute.
Whether a threat intended to deter a public official from performing lawful duties is a crime even if the official was not, at that exact moment, performing lawful duties.