Ariz. Rev. Stat. » Title 28
Arizona Revised Statutes

Ariz. Rev. Stat. § 28-622 (2026)

Failure to comply with police officer; classification

✓ current as of May 2026
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A. A person shall not wilfully fail or refuse to comply with any lawful order or direction of a police officer invested by law with authority to direct, control or regulate traffic.

B. A person who violates this section is guilty of a class 2 misdemeanor.

Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1984–2024 · leading case: State v. Burke, 360 P.3d 118 (Ariz. Ct. App. 2015).
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State v. Burke, 360 P.3d 118 (Ariz. Ct. App. 2015). · cites it 28× “” 3 Although the statute governing failure to comply with a police officer is found in Title 28, see A.R.S. § 28-622, the statutory definition of knowingly applies to the construction of offenses found outside of Title 13.”
Berkemer v. McCarty, 468 U.S. 420 (1984). · cites it 2× “[24] Examples of similar provisions in other States are: Ariz. Rev. Stat. Ann. §§ 28-622 , 28-622.”
United States v. Alfredo Landeros, 913 F.3d 862 (9th Cir. 2019). · cites it 3× “Because the police could not lawfully order the defendant to identify himself, the panel explained that the defendant’s repeated refusal to do so did not constitute a failure to comply with an officer’s lawful order under Ariz. Rev. Stat. Ann. § 28-622 (A). The panel concluded…”
State v. Gonzalez, 210 P.3d 1253 (Ariz. Ct. App. 2009). · cites it 11× “” We thus need consider only whether the offense outlined in AR.S. § 28-622 “is, by its very nature, always a constituent part of the greater offense.”
State of Arizona v. Francisco L. Encinas Valenzuela, 350 P.3d 811 (Ariz. Ct. App. 2015). · cites it 4× “01, 28-624(C); see also A.R.S. § 28-622(A) (“A person shall not willfully fail or refuse to comply with any lawful order or direction of a police officer invested by law with authority to direct, control or regulate traffic.”
Preston Seidner v. Jonathan De Vries, 39 F.4th 591 (9th Cir. 2022). “Ariz. Rev. Stat. § 28-622 . The concurrence argues that we err in describing Seidner as fleeing and that at summary judgment we must analyze this case on the premise that he was not fleeing because he disputed “that he intended to flee” and the video recording is inconclusive.”
Burnett v. Bottoms, 368 F. Supp. 2d 1033 (D. Ariz. 2005). · cites it 4× “” A.R.S. § 28-622(A). A person who violates this section is guilty of a class- 2 misdemeanor.”
Bressi v. Ford, 575 F.3d 891 (9th Cir. 2009). “§ 28-1595(B)(failure to provide a driver’s license or proof of identity) and Ariz.Rev. Stat. § 28-622(A)(failure to comply with a police officer’s lawful order).”
State v. Gendron, 804 P.2d 95 (Ariz. Ct. App. 1990). · cites it 2× “Failure to obey a lawful order of a police officer is *566 defined by A.R.S. § 28-622: “No person shall wilfully fail or refuse to comply with any lawful order or direction of any police officer invested by law with authority to direct, control or regulate traffic.”
State v. Dwyer (Ariz. Ct. App. 2016). · cites it 2× “Based upon the officer’s own observations, he had probable cause to believe Dwyer violated A.R.S. §§ 28-622 (failure to comply with a police officer) and -622.”
State v. Durazo (Ariz. Ct. App. 2016). · cites it 2× “01 (stating a person commits a class five felony if he “willfully flees or attempts to elude a pursuing official law enforcement vehicle”), with A.R.S. § 28-622 (specifying “[a] person shall not willfully fail or refuse to comply with any lawful order or direction of a police…”
Gonzalez v. Phoenix, City of (D. Ariz. 2024). “As he was pursuing Lopez, Stevens stated “you better f***ing 17 stop,” a lawful command by a police officer, which Lopez ignored in violation of Arizona 18 Revised Statutes § 28-622, and the video reflects Lopez throwing his iced tea over his 19 shoulder at Stevens, which…”
Show all 13 citing cases →
— Ariz. Rev. Stat. § 28-622(A) — 4 cases
State v. Burke, 360 P.3d 118 (Ariz. Ct. App. 2015). “” 3 Although the statute governing failure to comply with a police officer is found in Title 28, see A.R.S. § 28-622, the statutory definition of knowingly applies to the construction of offenses found outside of Title 13.”
State of Arizona v. Francisco L. Encinas Valenzuela, 350 P.3d 811 (Ariz. Ct. App. 2015). “01, 28-624(C); see also A.R.S. § 28-622(A) (“A person shall not willfully fail or refuse to comply with any lawful order or direction of a police officer invested by law with authority to direct, control or regulate traffic.”
Bressi v. Ford, 575 F.3d 891 (9th Cir. 2009). “§ 28-1595(B)(failure to provide a driver’s license or proof of identity) and Ariz.Rev. Stat. § 28-622(A)(failure to comply with a police officer’s lawful order).”
Burnett v. Bottoms, 368 F. Supp. 2d 1033 (D. Ariz. 2005). “” A.R.S. § 28-622(A). A person who violates this section is guilty of a class- 2 misdemeanor.”
— Ariz. Rev. Stat. § 28-622(B) — 1 case
Burnett v. Bottoms, 368 F. Supp. 2d 1033 (D. Ariz. 2005). “” A.R.S. § 28-622(A). A person who violates this section is guilty of a class- 2 misdemeanor.”
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