Illinois Appellate Court
Criminal Court
Obstruction of Justice
Defendant was convicted of two counts of resisting or obstructing a peace officer. One conviction, for obstructing, was based solely on Defendant's refusal to identify himself and refusal to provide identification. Criminal Code of 1961 does not impose a duty for a suspect to identify himself or herself, and thus a person cannot be convicted of obstructing a peace officer for merely refusing to identify himself and refusing to provide identification. (BURKE and SCHOSTOK, concurring.)