Not clearly established that deputy violated arrestee's Fourth Amendment rights in requiring him to identify himself during lawful traffic stop; N.B. there are three separate opinions in this case, including one dissent thus it’s unclear what precedential value it has with respect to the reasoning.
Refusing to provide identification to a police officer is not probable cause for arrest for obstruction under Illinois law; Hiibel v. Sixth District Court of Nevada, 542 U.S. 177 (2004) merely held that a state may pass a law that makes refusing to provide identification to police a crime, but Illinois law does not do that; but police here did have probable cause to arrest plaintiffs for trespass, defeating § 1983 claim for false arrest.