<Li> In four states (Arkansas, Florida, Georgia, and Rhode Island), failure to identify oneself is one factor to be considered in a decision to arrest . In all but Rhode Island, the consideration arises in the context of loitering or prowling . </Li> <Li> Seven states (Arizona, Florida, Indiana, Louisiana, New Mexico, Ohio, and Vermont) explicitly impose a criminal penalty for noncompliance with the obligation to identify oneself . </Li> <P> As of February 2011, the validity of a law requiring that a person detained provide anything more than stating his or her name has not come before the U.S. Supreme Court . </P> <P> In states whose "stop and identify laws" do not directly impose penalties, a lawful arrest must be for violation of some other law, such as one to the effect of "resisting, obstructing, or delaying a peace officer". For example, the Nevada "stop and identify" law challenged in Hiibel did not impose a penalty on a person who refused to comply, but the Justice Court of Union Township, Nevada, determined that Hiibels refusal to identify himself constituted a violation of Nevada "obstructing" law . A similar conclusion regarding the interaction between Utah "stop and identify" and "obstructing" laws was reached in Oliver v. Woods (10th Cir. 2000). </P>

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