PRESIDING JUSTICE O'MALLEY delivered the opinion of the court:

Following a bench trial in the circuit court of Du Page County, defendant, James Synnott, wasfound not guilty of driving under the influence of alcohol (DUI) (625 ILCS 5/11--501(a)(2) (West2002)), but was found guilty of speeding (625 ILCS 5/11--601(b) (West 2002)), failure to wear a seatbelt (625 ILCS 5/12--603.1 (West 2002)), and obstructing a peace officer (720 ILCS 5/31--1 (West2002)). On appeal, defendant challenges his conviction of obstructing a peace officer, arguing thatthe charging instrument and the evidence of guilt were both insufficient because the State neitheralleged nor proved that he committed a physical act. We affirm.

The complaint charging obstructing a peace officer alleged that defendant "knowinglyobstructed the performance of Kevin Driscoll Sr. of an authorized act within his official capacity,being the investigation of a potential intoxicated driver, knowing Kevin Driscoll Sr. to be a peaceofficer engaged in the execution of his official duties, in that he repeatedly refused to exit the car hewas driving when ordered by Kevin Driscoll Sr. to do so."

At trial, Officer Driscoll testified that he stopped defendant's vehicle after observing ittraveling about 20 miles per hour over the posted speed limit. Officer Driscoll noticed indicia of intoxication. After obtaining defendant's driver's license and evidence of insurance, Officer Driscollasked defendant to shut off his vehicle's engine and then walked back toward his squad car. Defendant did not comply, and Officer Driscoll returned to defendant's vehicle and repeated therequest and asked defendant "if he would prefer to sit on the curb." According to Officer Driscoll,the following exchange ensued:

"He then asked me if he was under arrest, and I asked him if he would prefer that. Hesaid no.

I asked him again then to shut off the engine. He shut off the engine. I thanked himand walked back to my car."

Officer Driscoll then summoned assistance, returned to defendant's vehicle, and askeddefendant to step out of the car. Defendant again asked if he was under arrest. Officer Driscollreplied, "no, you are not under arrest, but I need you to step out of the car." Defendant protestedthat his lawyer had told him "to never get out of the car." Officer Driscoll advised defendant that hehad a right to ask him to step out of the car and that defendant had no right to refuse. Defendantagain cited his lawyer's advice and refused to step out of the car. Once more, Officer Driscoll askeddefendant to step out of the vehicle and warned him that if he refused he would be arrested forobstructing a police officer. Defendant then grabbed the steering wheel with both hands. On directexamination, Officer Driscoll testified, "I then grabbed him by the left arm and started pulling on him;and within a matter of seconds, he let go of the steering wheel and exited the car." However, oncross-examination, Officer Driscoll testified that defendant exited the vehicle within a "split second"after he grabbed defendant's arm.

In finding defendant guilty of obstructing a peace officer, the trial court stated as follows:

"[T]he officer four times told the defendant to exit the vehicle, the defendantrepeatedly refused to do so. He grasped the steering wheel firmly at one point in an obviousindication he was refusing to leave the vehicle and after four occasions did not removehimself, and then momentarily did not comply with the officer pulling his arm; although hethen immediately did comply.

I believe that this many times refusing to comply with the officer's instructions doesconstitute the knowing instruction [sic] of the officer's performance of a duty, that is theinstruction to step out [sic] the vehicle when the defendant was lawfully detained for a trafficviolation and subject to being so directed by the officer to step out of the vehicle."

The trial court sentenced defendant to a one-year term of conditional discharge. The trialcourt denied defendant's posttrial motion, and this appeal followed.

Defendant argues that a conviction of obstructing a peace officer requires proof of a physical act and that merely refusing to comply with an officer's orders does not constitute obstruction. Accordingly, defendant contends that both the allegations of the charging instrument and the State'sevidence of guilt were insufficient to sustain his conviction.

Section 31--1(a) of the Criminal Code of 1961 (Code) (720 ILCS 5/31--1(a) (West 2002))provides that "[a] person who knowingly resists or obstructs the performance by one known to theperson to be a peace officer *** of any authorized act within his official capacity commits a Class Amisdemeanor." In People v. Raby, 40 Ill. 2d 392 (1968), the court observed that:

" ' "Resisting" or "resistance" means "withstanding the force or effect of " or the"exertion of oneself to counteract or defeat". "Obstruct" means "to be or come in the wayof". These terms are alike in that they imply some physical act or exertion. Given areasonable and natural construction, these terms do not proscribe mere argument with apoliceman about the validity of an arrest or other police action, but proscribe only somephysical act which imposes an obstacle which may impede, hinder, interrupt, prevent or delaythe performance of the officer's duties, such as going limp, forcefully resisting arrest orphysically aiding a third party to avoid arrest.' " Raby, 40 Ill. 2d at 399, quoting Landry v.Daley, 280 F. Supp. 938, 959 (N.D. Ill. 1968).

In Raby, the defendant's conviction was upheld where he went limp when the police arrested him fordisorderly conduct.

A number of cases have dealt with the refusal to obey various types of police orders. It hasbeen held that refusing to identify oneself or falsely identifying oneself in connection with a criminalmatter does not constitute resistance or obstruction. See People v. Ramirez, 151 Ill. App. 3d 731,735 (1986); People v. Weathington, 76 Ill. App. 3d 173, 174-75 (1979). On the other hand, thiscourt has held that a person named in a civil subpoena is obligated to identify himself to an officerattempting to serve the subpoena and can be prosecuted for obstruction if he fails to do so. Migliorev. County of Winnebago, 24 Ill. App. 3d 799, 802-03 (1974).

Migliore cited City of Chicago v. Meyer, 44 Ill. 2d 1 (1969), for the proposition that "[a]citizen may be found guilty of resisting or obstructing a police officer in the performance of his dutymerely by stating that he will not move on when requested to do so by a police officer." Migliore,24 Ill. App. 3d at 802. In Meyer, police ordered Vietnam war protesters and supporters to dispersewhen the police had become unable to maintain order among opposing factions and "the debate wasdegenerating to one of physical battle." Meyer, 44 Ill. 2d at 6. The defendant was arrested fordisobeying the order and was prosecuted under an ordinance imposing a fine on " '[a]ny person whoshall resist any officer of the police department in the discharge of his duties, or shall in any wayinterfere with or hinder or prevent him from discharging his duty as such officer.' " Meyer, 44 Ill. 2dat 5. Our supreme court held that "defendant was properly convicted of interfering with the policein the discharge of their duty to maintain order." Meyer, 44 Ill. 2d at 6.

In contrast, in People v. Stoudt, 198 Ill. App. 3d 124 (1990), this court held that criminalcomplaints alleging that the defendants " 'knowingly refused *** to remove [themselves] from the 400block of Lincoln Highway, De Kalb, De Kalb County, Illinois, after being instructed to do so by [aDe Kalb police officer]' " did not charge the offense of resisting a peace officer. Noting that thedefendants allegedly refrained from any physical action, we held that there were no physical acts ofresistance. Stoudt, 198 Ill. App. 3d at 127. We also noted that the complaints were deficient becausethey did not properly allege that the officer was engaged in an authorized act. Stoudt, 198 Ill. App.3d at 128.

In People v. Hilgenberg, 223 Ill. App. 3d 286 (1991), numerous defendants were charged withobstructing a peace officer based on allegations that they refused to open the door of a privateresidence to an officer who sought to investigate a report of underage drinking. Citing Stoudt, thiscourt stated that the defendants' inaction should not be deemed an act of physical resistance. However, we identified another facet to the question of what behavior--be it an act or a failure orrefusal to act--constitutes resisting or obstructing:

"The difficulty in determining whether action or inaction is punishable, we believe,stems at least in part from attempting to analyze the lawfulness of an action or inactionoutside the context of the statute: the act of obstructing or resisting must be in response toan authorized act of the officer. Certainly, the inaction of the occupants of a house orbuilding, without more, has no legal significance. On the other hand, a failure to respond toan officer's request to open a door or to permit entry to the premises only has legalsignificance if the request was authorized within his official capacity and the response of thedefendant actually impeded an act the officer was authorized to perform." (Emphasis inoriginal.) Hilgenberg, 223 Ill. App. 3d at 290.

Based on this reasoning, we held that no offense had been committed because the officer hadauthority to request to enter the premises but not to demand entry, and the occupants were withintheir rights in refusing to admit the officer. Similarly, in People v. Cope, 299 Ill. App. 3d 184 (1998),we relied on Hilgenberg in holding that a restaurant owner was not guilty of obstruction based onevidence that she refused to unlock the door to the restaurant for police officers seeking to takecustody of a runaway teenager who had sought refuge inside the establishment.

Having reviewed these cases, we do not believe that the distinction between acting andrefraining from action is dispositive. Although it is true that Raby spoke in terms of a "physical act"of obstruction or resistance, it is also true that in common usage in the criminal law context, the word"act" is used broadly and is understood to include "a failure or omission to take action" (720 ILCS5/2--2 (West 2002)). This reading is consistent with Raby's definition of " 'obstruct[ion]' " as " 'tobe or come in the way of.' " (Emphasis added.) Raby, 40 Ill. 2d at 399, quoting Landry, 280 F.Supp. at 959. Whereas "to ***come in the way of" connotes obstruction through motion, "to be ***in the way of" connotes, in contradistinction, obstruction by remaining stationary. Moreover, Meyerteaches that merely refusing a police officer's lawful order to move can constitute interference withthe officer in the discharge of his or her duty. The words "interference" and "obstruction" are nearlysynonymous (see Webster's Third New International Dictionary 1178 (1993)), and if the former mayconsist of inaction, we see no reason why the latter may not also.

Stoudt does not affect our conclusion because it merely dealt with the question of whetherthe refusal to move can constitute an act of resistance. We did not specifically consider the separatedefinition of obstruction, as was charged here. Moreover, as seen, our subsequent cases, Hilgenbergand Cope, have focused, not on whether the conduct charged was action or inaction, but on whetherthe officer was engaged in an authorized act and whether the defendant impeded that act. We alsocannot ignore the practical consequences of ruling differently. If a civilian whose presence at aparticular location impedes lawful police activity may refuse to move without fear of prosecution,confrontations with police are far more likely to achieve a physical dimension, substantially increasingthe physical danger to both the officer and the civilian. Certainly officers are authorized to usereasonable physical force if necessary, but it is clearly preferable to obtain compliance through thethreat of criminal penalties. Stated differently, it cannot be good policy to remove the only stick thatthe police have, other than the billy club itself, to persuade such recalcitrant individuals. Althoughdefendant correctly notes that he might have been charged with failure to obey an order of a policeofficer under section 11--203 of the Illinois Vehicle Code (625 ILCS 5/11--203 (West 2002)), thatfact does not eliminate these practical consequences of his interpretation of section 31--1(a) of theCode in situations outside the scope of the Illinois Vehicle Code.

In view of the foregoing, we conclude that the complaint sufficiently charged the offense ofobstructing a peace officer and that the State produced sufficient evidence to sustain a conviction ofthat offense. As discussed, the complaint alleged that defendant knowingly obstructed the arrestingofficer's investigation of a possible crime (DUI) by repeatedly refusing to comply with the officer'sorder that defendant exit his vehicle. Following a lawful traffic stop, the police may, as a matter ofcourse, order the driver and the passengers out of the vehicle pending the completion of the stopwithout violating the protections of the fourth amendment. Maryland v. Wilson, 519 U.S. 408, 137L. Ed. 2d 41, 117 S. Ct. 882 (1997); People v. Gonzalez, 184 Ill. 2d 402, 413-14 (1998). The ruleis based on considerations of officer safety. It seems clear that any behavior that actually threatensan officer's safety or even places an officer in fear for his or her safety is a significant impediment tothe officer's performance of his or her duties. For these reasons, we cannot endorse the reasoningor result in the Fifth District's decision in People v. Flannigan, 131 Ill. App. 2d 1059 (1971), heavilyrelied on by defendant, which dismissed a motorist's repeated refusal to emerge from his car afterbeing placed under arrest as "at most an insubstantial display of antagonism or belligerence." Flannigan, 131 Ill. App. 2d at 1063. In our view, a meaningful threat of prosecution for the sort ofnoncooperation in Flannigan and the present case is necessary to reduce the likelihood of physicalconfrontations. We therefore hold that the complaint was sufficient.

Turning to the sufficiency of the evidence, we note that a criminal conviction will not be setaside unless the evidence is so improbable or unsatisfactory that it creates a reasonable doubt of thedefendant's guilt. People v. Collins, 106 Ill. 2d 237, 261 (1985). In reviewing the sufficiency of theevidence, " 'the relevant question is whether, after viewing the evidence in the light most favorableto the prosecution, any rational trier of fact could have found the essential elements of the crimebeyond a reasonable doubt.' " (Emphasis in original.) Collins, 106 Ill. 2d at 261, quoting Jacksonv. Virginia, 443 U.S. 307, 319, 61 L. Ed. 2d 560, 573, 99 S. Ct. 2781, 2789 (1979). For the reasonsdiscussed above, the evidence that defendant repeatedly disobeyed the arresting officer's order to exitthe vehicle is sufficient to sustain a conviction of obstructing a peace officer. Defendant argues that the evidence does not show that he was ordered to exit the vehicle. According to defendant, thearresting officer merely requested that he step out of the vehicle. The argument is meritless. Thearresting officer did not merely ask defendant to step out of the car. He told defendant that he"needed" him to step out of the car, that defendant had no right to refuse the request, and thatdefendant would be arrested for obstructing a peace officer if he did not comply.

For the foregoing reasons, the judgment of the circuit court of Du Page County is affirmed.

Affirmed.

BOWMAN and GROMETER, JJ., concur.