Brian V. Milazzo Missouri Cases

Brian Milazzo appealed his conviction for interfering with an arrest, arguing there was insufficient evidence that his refusal to unlock his vehicle's passenger-side door constituted physical interference. The Missouri Supreme Court affirmed the circuit court's judgment. The Court held that Milazzo's refusal to unlock the door, thereby creating a material barrier between officers and the passenger, constituted physical interference under the statute, as a reasonable jury could find such actions impeded an arrest.

Brian Milazzo appealed his conviction for interfering with an arrest, stemming from his failure to unlock his vehicle door when officers attempted to arrest his passenger for a seatbelt infraction. The trial court had denied Milazzo's motions for judgment of acquittal. The Western District of the Missouri Court of Appeals reversed the conviction, holding that Milazzo's inaction did not constitute "physical interference" under section 575.150.1, especially since the officers had possession of the vehicle keys and could have unlocked the door themselves.