In the wake of Eric Garner's death, the head of the NYC Patrolmen's Benevolent Association, a police interest group, blamed Garner: "You cannot resist arrest, that's a crime." But it's not a crime that most police officers often file reports about.

The New York Police Department is made up of 35,000 officers, and just a minority of them have sent people into court for "resisting arrest."

But the ones who do, according to a new report from WNYC, charge a lot of people — and that can be a "red flag" for other issues.

WNYC looked at over 51,000 cases where someone was charged with "resisting arrest" since 2009. They found that 40 percent of those cases — over 20,000 — were committed by just 5 percent of all the police officers on the force. And 15 percent of officers accounted for a majority of all "resisting arrest" charges.

Why "resisting arrest" cases matter

The upshot of this data is that charging people with "resisting arrest" is something most cops do very rarely, and a few cops do a lot. Here's why that matters: if a cop is routinely hauling people into court for resisting arrest, he might be taking an overly aggressive attitude toward civilians. A police officer might even, as police accountability expert Sam Walker told WNYC, use the criminal charge to cover up his use of excessive force:

"There's a widespread pattern in American policing where resisting arrest charges are used to sort of cover - and that phrase is used - the officer's use of force," said Walker, the accountability expert from the University of Nebraska. "Why did the officer use force? Well, the person was resisting arrest."

That pattern held up in the case of Donald Sadowy, a Brooklyn police officer who's the subject of the WNYC article. Sadowy has more than 20 resisting arrest cases since 2009 — putting him in the 98th percentile, or higher, among all police. Meanwhile, over the last two years, Sadowy's been sued 10 times for excessive force.