Risbridger v. Connelly, 275 F.3d 565, 572 (6th Cir.2002); Gainor v. Rogers, 973 F.2d 1379, 1386 n. 10 (8th Cir.1992); Tom v. Voida, 963 F.2d 952, 959 & n. 8 (7th Cir.1992). The Tenth Circuit has adopted a different view of the open question, concluding that because the law is not clearly established that a citizen may refuse to answer questions during an investigative stop, the officer could lawfully arrest the person for failure to comply. Oliver v. Woods, 209 F.3d 1179, 1189-90 (10th Cir.2000). The Ninth Circuit has ruled that arresting a person for refusing to provide his or her name violates the Fourth Amendment, but this position has not been adopted by other federal Courts of Appeals or the Supreme Court. See Carey v. Nevada Gaming Control Bd., 279 F.3d 873, 881-82 (9th Cir.2002) (<HOLDING>); see also Risbridger, 275 F.3d at 572
holding fourth amendment protects against use of force while in arresting officers custody until arraignment or formal charge holding that false arrest supports a claim against state police under  1983 because it violates the fourth amendment holding that a person is presumed to own all property that is titled in her name holding arresting a person for refusing to provide his or her name violates the fourth amendment holding that fourth amendment seizure continues throughout the time the person remains in the custody of the arresting officers