United Statesv.Tia Deyon Pugh
During a 2020 Mobile protest that devolved into a riot near Interstate 10, Tia Pugh used a baseball bat to smash a police car blocking the interstate ramp, diverting officers from the barricade. A jury convicted her under 18 U.S.C. § 231(a)(3), which bars intentionally obstructing law enforcement during a civil disorder affecting interstate commerce. The Eleventh Circuit affirmed, rejecting Pugh’s facial challenges under the Commerce Clause, the First Amendment’s overbreadth and content-neutrality rules, and the Fifth Amendment’s vagueness doctrine. It held that the statute’s interstate-commerce element limits it to valid applications and that “obstruct,” “impede,” and “interfere” together require hindering officers through more than mere words. The court found the statute content-neutral and Pugh had not shown substantial unconstitutional applications, but it left open whether some expressive acts that physically obstruct police could be covered. Because disabling the police car during the riot clearly fell within the statute, Pugh could not press a facial vagueness challenge based on possible applications to others. Her conviction and sentence were affirmed.
Loading published copy…

