State v. Taylor, 212 N.C. App. 238 (Jun. 7, 2011)

(1) By enacting G.S. 14-223 (resist, delay, obstruct an officer), the General Assembly did not deprive the State of the ability to prosecute a defendant for common law obstruction of justice, even when the defendant’s conduct could have been charged under G.S. 14-223. (2) In a case in which the defendant, a sheriff’s chief deputy, was alleged to have obstructed justice by interfering with police processing duties in connection with a DWI charge against a third-person, the trial judge did not err by failing to instruct the jury on the lack of legal authority to require the processing with which the defendant allegedly interfered.