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

Ariz. Rev. Stat. § 28-622 (2026)

Failure to comply with police officer; classification

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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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× “The panel concluded that there was therefore no justification for the extension of the detention to allow the officers to press the defendant further for his identity.”
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). “Construing the facts in the light most favorable to Seidner does not require us to turn a blind eye to established facts that “clearly contradict[]” his telling of events. Rice, 989 F.3d at 1120 (citation and internal quotation marks omitted); see also Scott v.”
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, No. 1 CA-CR 15-0141 (Ariz. Ct. App. Mar. 10, 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, No. 1 CA-CR 15-0373 (Ariz. Ct. App. Apr. 28, 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, No. 2:21-cv-01340 (D. Ariz. Mar. 20, 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…”
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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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