ROBB, J.
Maddox Macy appeals her conviction for resisting law enforcement, a Class A misdemeanor. Macy raises a single issue for our review: whether there was sufficient evidence to prove Macy forcibly resisted a law enforcement officer. Concluding Macy did not forcibly resist, we reverse.
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Macy’s hands were handcuffed behind her back, and Officer Bowland placed Macy in the front seat of his police car and shut the door. Macy somehow opened the door, got out of the car, and began yelling once again. Officer Bowland requested that Macy get back in the police car, but she refused. Officer Bowland “had to force [Macy] into the car and she sat down and kept her feet out on the ground.” Id. at 38. Officer Bowland asked Macy to place her feet inside the vehicle, but she refused, so the officer “had to pick her feet up, put her feet into the car and shut the door.” Id.
When asked whether Macy ever “physically” resisted, Officer Bowland testified that “[Macy] resisted my, my commands. She wouldn’t get back into the car. . . . [S]he refused and I had to place her in the car and then she wouldn’t put her feet into the car. I had to place her feet into the car.” Id. at 43.
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. . . [E]ach case affirming a conviction of forcible resistance seems to involve, at a minimum, some physical interaction with a law enforcement officer. We believe that a plain, commonsense reading of the phrase “forcibly resists” contemplates such interaction. See Ind. Code § 35-44.1-3-1(a)(1). When Macy opened the car door, Officer Bowland was not in the immediate vicinity; Macy’s act of opening the car door did not involve any interaction with Officer Bowland, nor was it directed toward him or did it present a threat to him. While it is possible that Macy’s conduct may qualify as some other crime, it was not a crime of forcible resistance.
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Here, we believe Macy’s refusal to place her feet inside the vehicle was an act of passive resistance that is not punishable under Indiana Code section 35-44.1-3-1(a)(1). Macy’s act of resting her feet on the ground is akin to a refusal to stand or some other passive action that we said in A.C. would not qualify as forcible resistance. [Footnote omitted.]
Finally, we would be remiss not to address the State’s claim that forcible resistance by Macy may be reasonably inferred based on Officer Bowland’s testimony that he had to “force” Macy back into the car and physically pick up her feet and place them in the vehicle. We disagree for two reasons. First, an officer’s use of force does not establish that the defendant forcibly resisted. A.C., 929 N.E.2d at 911 n.2; see also Colvin, 916 N.E.2d at 309. Second, on cross-examination, Officer Bowland was asked whether Macy ever physically resisted him, at which point Officer Bowland clarified that Macy resisted his commands. In light of that testimony, we do not believe the evidence supports the State’s proposed inference. Indeed, the facts before us are nearly identical to those in Colvin, where the officer testified that the defendant was not complying with officers’ commands and the officers used some degree of force in response. See 916 N.E.2d at 308-09. We reach the same conclusion here as we did in Colvin: the defendant’s conviction for resisting law enforcement must be reversed.
BAKER, J., and KIRSCH, J., concur.