Code of Alabama
Ala. Code § 13A-8-194 (2026)
Obstructing Justice Using a False Identity.
✓ official Alabama Legislature (ALISON) text, current July 2026
(a) A person commits the crime of obstructing justice using a false identity if he or she uses identification documents or identifying information of another person or a fictitious person to avoid summons, arrest, prosecution, or to impede a criminal investigation.
(b) Obstructing justice using a false identity is a Class C felony.
(Act 2001-312, p. 399, §5.)
Notes of Decisions
Cited in 11
cases (3 in the last 5 years), 2003–2023 · leading case: Ishola v. State, 945 A.2d 1273 (Md. 2008).
Ishola v. State, 945 A.2d 1273 (Md. 2008). “Ala.Code § 13A-8-194(a) (1975) is a good example of a Legislature's intent to expand the meaning of "false identity" to expressly include the term "fictitious person.”
Pruitt v. State, 954 So. 2d 611 (Ala. Crim. App. 2006). “Code 1975; unlawful use or possession with the intent to use drug paraphernalia, a violation of § 13A-12-260(c), Ala.Code 1975; and unlawful possession of a controlled substance, cocaine, a violation of § 13A-12-212(a)(1), Ala.”
J.D.I. v. State, 77 So. 3d 610 (Ala. Crim. App. 2011). “, pleaded guilty as a youthful offender to one count of obstructing justice by using a false identity, a violation of § 13A-8-194, Ala.Code 1975. He was sentenced to two years’ imprisonment; that sentence was suspended, and he was ordered to serve one year of supervised…”
State v. Worley, 102 So. 3d 408 (Ala. Crim. App. 2009). “2009), the State made only a general objection to the trial court’s dismissal of the indictment charging Toole with obstructing justice by using a false identity, a violation of § 13A-8-194, Ala. Code 1975. This Court held: “In the present case, the trial court was clearly aware…”
State v. Toole, 25 So. 3d 486 (Ala. Crim. App. 2009). “Toole with obstructing justice by using a false identity, in violation of § 13A-8-194, Ala.Code 1975. On February 9, 2008, Thelma Toole was the passenger in an automobile pulled over by the police.”
Smith v. State, 869 So. 2d 1189 (Ala. Crim. App. 2003). “The record reveals that on January 22, 2002, Smith was convicted of obstruction of justice by using a false identity, a violation of § 13A-8-194, Ala.Code 1975. He was sentenced to imprisonment for one year and a day; however, the district court ordered that the sentence be…”
Kenneth Alan Vandusen v. State of Alabama (Ala. Crim. App. 2023). “Code 1975, and obstructing justice CR-2022-0571 by using a false identity, a violation of § 13A-8-194, Ala. Code 1975.1 The trial court sentenced Vandusen, as a habitual felony offender, to concurrent sentences of 20 years' imprisonment and then split the sentences, ordering…”
Williams v. United States (N.D. Ala. 2023). “On July 22, 2018, Williams was arrested by an officer of the Pelham Police Department on charges of Obstruction of Justice – False Identification, in violation of Ala. Code § 13A-8-194, and placed in custody in Shelby County, Alabama.”
Byner v. State (In re Byner), 270 So. 3d 1162 (Ala. 2018). “Code 1975, and one count of obstructing justice using a false identity, see § 13A-8-194, Ala. Code 1975. We issued the writ of certiorari in order to determine as an issue of first impression whether robbery is a crime involving "dishonesty or false statement" for purposes of…”
Hall v. Valenza (INMATE 3) (M.D. Ala. 2022). “CODE § 13A-8-194. Doc. No. 10-3 at 1; Doc. No.”
Byner v. State (In re Byner), 270 So. 3d 1162 (Ala. 2018). “Code 1975, and one count of obstructing justice using a false identity, see § 13A-8-194, Ala. Code 1975. We issued the writ of certiorari in order to determine as an issue of first impression whether robbery is a crime involving "dishonesty or false statement" for purposes of…”
Ala. Code § 13A-8-194(a): 2 cases
Ishola v. State, 945 A.2d 1273 (Md. 2008). “Ala.Code § 13A-8-194(a) (1975) is a good example of a Legislature's intent to expand the meaning of "false identity" to expressly include the term "fictitious person.”
Kenneth Alan Vandusen v. State of Alabama (Ala. Crim. App. 2023). “Code 1975, and obstructing justice CR-2022-0571 by using a false identity, a violation of § 13A-8-194, Ala. Code 1975.1 The trial court sentenced Vandusen, as a habitual felony offender, to concurrent sentences of 20 years' imprisonment and then split the sentences, ordering…”
Ala. Code § 13A-8-194(b): 1 case
Kenneth Alan Vandusen v. State of Alabama (Ala. Crim. App. 2023). “Code 1975, and obstructing justice CR-2022-0571 by using a false identity, a violation of § 13A-8-194, Ala. Code 1975.1 The trial court sentenced Vandusen, as a habitual felony offender, to concurrent sentences of 20 years' imprisonment and then split the sentences, ordering…”
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