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Keywords

statuteself-incriminationseizure
statuteself-incriminationseizure

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Hiibel v. Sixth Judicial Dist. Court of Nevada, Humboldt County, 542 U.S. 177, 124 S.Ct. 2451, 159 L.Ed.2d 292, 72 USLW 4509, 04 Cal. Daily Op. Serv. 5378, 2004 Daily Journal D.A.R. 7363, 17 Fla. L. Weekly Fed. S 406

Facts

The case arose when a sheriff's department in Humboldt County, Nevada, received a report of an assault involving a man and a woman in a truck. Deputy Sheriff Lee Dove arrived at the scene and found Hiibel, who appeared intoxicated, standing by the truck. When asked for identification, Hiibel refused multiple times, leading to his arrest for obstructing the officer in the performance of his duties under Nevada law. Hiibel was subsequently convicted for his refusal to identify himself.

The case arose when a sheriff's department in Humboldt County, Nevada, received a report of an assault involving a man and a woman in a truck. Deputy Sheriff Lee Dove arrived at the scene and found Hiibel, who appeared intoxicated, standing by the truck. When asked for identification, Hiibel refused multiple times, leading to his arrest for obstructing the officer in the performance of his duties under Nevada law.

Issue

Did Hiibel's conviction for refusing to identify himself during a lawful investigative stop violate his Fourth Amendment rights against unreasonable searches and seizures and his Fifth Amendment right against self-incrimination?

Did Hiibel's conviction for refusing to identify himself during a lawful investigative stop violate his Fourth Amendment rights against unreasonable searches and seizures and his Fifth Amendment right against self-incrimination?

Rule

The Supreme Court held that a state may require a suspect to disclose his name during a Terry stop, as long as the stop is justified at its inception and reasonably related in scope to the circumstances justifying the stop.

The Supreme Court held that a state may require a suspect to disclose his name during a Terry stop, as long as the stop is justified at its inception and reasonably related in scope to the circumstances justifying the stop.

Analysis

The Court found that the initial stop of Hiibel was based on reasonable suspicion, satisfying Fourth Amendment requirements. The Nevada statute requiring disclosure of identity was deemed narrower and more precise than those invalidated in previous cases, as it only required a suspect to state his name without necessitating additional identification documents. The Court concluded that the request for identity was directly related to the purpose of the stop and did not constitute an unreasonable seizure.

The Court found that the initial stop of Hiibel was based on reasonable suspicion, satisfying Fourth Amendment requirements. The Nevada statute requiring disclosure of identity was deemed narrower and more precise than those invalidated in previous cases, as it only required a suspect to state his name without necessitating additional identification documents.

Conclusion

The U.S. Supreme Court affirmed the Nevada Supreme Court's ruling, concluding that Hiibel's conviction did not violate his Fourth or Fifth Amendment rights.

The U.S. Supreme Court affirmed the Nevada Supreme Court's ruling, concluding that Hiibel's conviction did not violate his Fourth or Fifth Amendment rights.

Who won?

The State of Nevada prevailed in the case, as the Supreme Court upheld the constitutionality of the 'stop and identify' statute, affirming that requiring a suspect to disclose their name during a lawful stop does not violate constitutional protections.

The State of Nevada prevailed in the case, as the Supreme Court upheld the constitutionality of the 'stop and identify' statute, affirming that requiring a suspect to disclose their name during a lawful stop does not violate constitutional protections.

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