conduct that is arguably more similar to this. First is an older case decided by the D.C. Circuit and also identified in the defense’s brief, United States v. Cunningham, 509 F.2d 961 (D.C. Cir. 1975) (per curiam). The Cunningham court recognized that “not all failures to cooperate with federal agents are within [section Ill’s] prohibition, and that some measure of presently applied force is required.” Id. at 963. “Whether a person has opposed the efforts of federal agents with sufficient force to engage the statute can thus be a troublesome question of degree.” Id. Falling short, the D.C. Circuit presumed, “would be the mere refusal to unlock a door through which federal agents sought entrance.” Id. (citing District of Columbia v. Little, 339 U.S. 1, 70 S.Ct. 468, 94 L.Ed. 599 (1950) (<HOLDING>)). Nevertheless, the force involved in the
holding that relative to the threat that she posed physically separating tina cortez from her telephone taking her by the arm  escorting her from her home taking the keys to her home and locking the door and  placing her in the locked back seat of a patrol car was excessive force as well as an unlawful seizure under the fourth amendment holding that police officers did not violate the fourth amendment by telephoning an individual and threatening to seize a motorcycle in her possession and to arrest her without a warrant holding that threatening employee to mind her own business investigating her videotaping her without her permission and forcing her to take polygraph could not be considered adverse employment actions because they had no effect on conditions of employment holding that the word interfere in a dc regulation criminalizing the interfering with or preventing of building inspections by health officers could not be interpreted to encompass respondents failure to unlock her door and her remonstrances on fourth amendment grounds holding that the word interfere in the regulation could not p 7 fairly be interpreted to encompass the respondents failure to unlock her door and her remonstrances on constitutional grounds