Ark. Code Ann. » Title 5 Chapter 54
Arkansas Code Annotated

Ark. Code Ann. § 5-54-102 (2026)

Obstructing governmental operations

✓ current as of May 2026
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  1. A person commits the offense of obstructing governmental operations if the person:
    1. Knowingly obstructs, impairs, or hinders the performance of any governmental function;
    2. Knowingly refuses to provide information requested by an employee of a governmental agency relating to the investigation of a case brought under Title IV-D of the Social Security Act, 42 U.S.C. § 651 et seq., and is the physical custodian of the child in the case;
    3. Fails to submit to court-ordered scientific testing by a noninvasive procedure to determine the paternity of a child in a case brought under Title IV-D of the Social Security Act, 42 U.S.C. § 651 et seq.; or
    4. Falsely identifies himself or herself to a law enforcement officer or a code enforcement officer.
    1. Obstructing governmental operations by using or threatening to use physical force is a Class A misdemeanor.
    2. A second or subsequent offense of obstructing governmental operations under subdivision (a)(4) of this section is a Class A misdemeanor.
    3. Otherwise, obstructing governmental operations is a Class C misdemeanor.
  3. This section does not apply to:
    1. Unlawful flight by a person charged with an offense;
    2. Refusal to submit to arrest;
    3. Any means of avoiding compliance with the law not involving affirmative interference with a governmental function unless specifically set forth in this section; or
    4. Obstruction, impairment, or hindrance of what a person reasonably believes is a public servant's unlawful action.
    1. As used in this section, “code enforcement officer” means an individual charged with the duty of enforcing a municipal code, municipal ordinance, or municipal regulation as defined by a municipal code, municipal ordinance, or municipal regulation.
    2. “Code enforcement officer” includes a municipal animal control officer.

History. Acts 1975, No. 280, § 2802; A.S.A. 1947, § 41-2802; Acts 1995, No. 1182, § 1; 1999, No. 577, § 1; 2005, No. 1994, § 453; 2007, No. 163, § 1; 2009, No. 342, § 1; 2009, No. 748, § 25.

Amendments. The 2009 amendment by No. 342 inserted “or a code enforcement officer” in (a)(4) and made a related change; and added (d).

The 2009 amendment by No. 748 made stylistic changes in (b)(2).

Research References

ALR.

Criminal and Civil Liability of Civilians and Police Officers Concerning Recording of Police Actions. 84 A.L.R.6th 89.

Case Notes

Evidence Held Insufficient.

Where arrestee who sued police officer and city under 42 U.S.C. § 1983 alleged that he was arrested merely because (1) he watched the police officer as he spoke with two young men from a distance, (2) during the incident arrestee spoke only when spoken to, and (3) arrestee complied with a request for identification, and where police officer admitted some of those facts but asserted that arrestee was arrested only after he refused to move, the court properly denied officer summary judgment based on qualified immunity; under those circumstances, no officer reasonably could have believed he had probable cause to arrest the arrestee for obstruction of justice or any other offense. Walker v. City of Pine Bluff, 414 F.3d 989 (8th Cir. 2005).

Evidence Held Sufficient.

Evidence that defendant exited his residence and began screaming at officers who were investigating a possible drunk driver who had been stopped in defendant's driveway, causing the suspect to stop cooperating with the police investigation, was sufficient to support defendant's conviction of obstructing governmental operations. Kelley v. State, 75 Ark. App. 144, 55 S.W.3d 309 (2001).

Obstruction adjudication was supported by the evidence, because the juvenile was given a lawful command to return to his room by a law-enforcement officer and failed to abide by it. R.B. v. State, 2013 Ark. App. 377 (2013).

Search and Seizure.

Vehicle passenger, who was allegedly arrested by a state police officer for refusing to provide identification, stated a claim against the officer for a Fourth Amendment violation. There was no probable cause to arrest the passenger under subdivision (a)(1) of this section for obstructing the performance of a governmental function; the officer's authority under Ark. R. Crim. P. 2.2 to request information did not provide probable cause because there was no showing that the passenger had a duty under Arkansas law to furnish identification. Stufflebeam v. Harris, 521 F.3d 884 (8th Cir. 2008).

Cited: Price v. State, 276 Ark. 80, 632 S.W.2d 429 (1982); Robinson v. Beaumont, 291 Ark. 477, 725 S.W.2d 839 (1987); Nelson v. State, 2013 Ark. App. 421 (2013).

Notes of Decisions
Cited in 23 cases (13 in the last 5 years), 2001–2026 · leading case: Fowler v. State, 371 S.W.3d 677 (Ark. 2010).
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Fowler v. State, 371 S.W.3d 677 (Ark. 2010). · cites it 4× “For these reasons, I would hold that Fowler violated the obstructing governmental operations statute at Arkansas Code Annotated section 5-54-102(a)(1), when he fled from Officer Sehichtl and Officer Burnett after they lawfully stopped him to ask him his name.”
Kelley v. State, 55 S.W.3d 309 (Ark. Ct. App. 2001). · cites it 4× “Ark. Code Ann. § 5-54-102 (b) (Repl. 1997).”
Turman v. State, 467 S.W.3d 181 (Ark. Ct. App. 2015). · cites it 2× “2013); Ark.Code Ann. § 5-54-102(a)(4) (Supp. 2013).”
Doralee Keeton v. State of Arkansas, 2026 Ark. App. 53 (Ark. Ct. App. 2026). · cites it 6× “8 Ark. Code Ann. § 5-54-102 (a)(1) (Repl. 2016).”
Kenneth Hunt v. Dale Acosta, 109 F.4th 1003 (8th Cir. 2024). “” Ark. Code § 5-54-102(a)(1). “When the constitutional validity of an arrest is challenged, it is the function of a court to determine whether the facts available to the officers at the moment of the arrest would ‘warrant a man of reasonable caution in the belief’ that an…”
Joshua Miller v. State of Arkansas, 2022 Ark. App. 351 (Ark. Ct. App. 2022). · cites it 2× “Ark. Code Ann. § 5-54-102 (a)(1) (Repl. 2016).”
Joshua Miller v. State of Arkansas, 2022 Ark. App. 351 (Ark. Ct. App. 2022). · cites it 2× “Ark. Code Ann. § 5-54-102 (a)(1) (Repl. 2016).”
Gary G. Seyller, Jr. v. State of Arkansas, 2019 Ark. App. 423 (Ark. Ct. App. 2019). · cites it 2× “§ 5-37-209 (b)(1)(A), a Class A misdemeanor; (3) obstruction of governmental operations under Ark. Code Ann. § 5-54-102 (b)(1), a Class A misdemeanor; (4) driving with a suspended license under Ark.”
Alexander Sullivan, in His Individual & Off. Capacities; City of Little Rock; & Keith Humphrey, in His Off. Capacity as Chief of Police, City of Little Rock Police Dep't v. Kenneth Richardson, 2026 Ark. App. 145 (Ark. Ct. App. 2026). · cites it 8× “The undisputed record—particularly Sullivan’s dashcam audio—demonstrates that Richardson exited his vehicle and approached Sullivan during an active investigatory stop of a potentially armed aggravated-robbery suspect, refused repeated directives to leave, and diverted…”
Brown v. Helder (W.D. Ark. 2019). · cites it 4× “” Ark. Code Ann. § 5-54-102 (a)(1). The section does not apply to a “refusal to submit to arrest; [or] [a]ny means of avoiding compliance with the law not involving affirmative interference with a governmental function unless specifically set forth in this section.”
Moises A. Quinteros-Orellana v. Deon T. Clay (W.D. Ark. 2026). · cites it 4× “” Ark. Code Ann. § 5-54-102 . Governmental function is defined as “any activity that a public servant is legally authorized to undertake on behalf of any governmental unit he or she serves.”
James Tanner v. Kurt Ziegenhorn (8th Cir. 2023). · cites it 2× “See Ark. Code Ann. § 5-54-102 (a)(1). Trooper Ziegenhorn, who was a witness at the trial, testified that Tanner moved his right hand toward his gun during the encounter.”
Show all 23 citing cases →
— Ark. Code Ann. § 5-54-102(a)(1) — 4 cases
Fowler v. State, 371 S.W.3d 677 (Ark. 2010). “For these reasons, I would hold that Fowler violated the obstructing governmental operations statute at Arkansas Code Annotated section 5-54-102(a)(1), when he fled from Officer Sehichtl and Officer Burnett after they lawfully stopped him to ask him his name.”
Kenneth Hunt v. Dale Acosta, 109 F.4th 1003 (8th Cir. 2024). “” Ark. Code § 5-54-102(a)(1). “When the constitutional validity of an arrest is challenged, it is the function of a court to determine whether the facts available to the officers at the moment of the arrest would ‘warrant a man of reasonable caution in the belief’ that an…”
Garner v. Green (E.D. Ark. 2022).
Gavonna Willis v. Juanita Mills, 141 F.4th 905 (8th Cir. 2025).
— Ark. Code Ann. § 5-54-102(a)(4) — 1 case
Turman v. State, 467 S.W.3d 181 (Ark. Ct. App. 2015). “2013); Ark.Code Ann. § 5-54-102(a)(4) (Supp. 2013).”
— Ark. Code Ann. § 5-54-102(a)(l) — 2 cases
Fowler v. State, 371 S.W.3d 677 (Ark. 2010). “For these reasons, I would hold that Fowler violated the obstructing governmental operations statute at Arkansas Code Annotated section 5-54-102(a)(1), when he fled from Officer Sehichtl and Officer Burnett after they lawfully stopped him to ask him his name.”
Kelley v. State, 55 S.W.3d 309 (Ark. Ct. App. 2001). “Ark. Code Ann. § 5-54-102 (b) (Repl. 1997).”
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