Hiibel held that statutes requiring suspects to disclose their names during police investigations did not violate the Fourth Amendment if the statute first required reasonable and articulable suspicion of criminal involvement. The Wisconsin Supreme Court held in Henes v. Morrissey that "A crime is made up of two parts: proscribed conduct and a prescribed penalty. "The former without the latter is no crime. ... In this case no statute penalizes a refusal to identify oneself to a law enforcement officer, and no penalty is set forth in the statute for refusing to identify oneself. This statute is part of Chapter 968 entitled "Commencement of Criminal Proceedings. By its very terms sec. 968.24 empowers a law enforcement officer to stop and question "in the vicinity where the person was stopped." The statute does not authorize a law enforcement officer to make an arrest."(These quotes comes from the dissenting opinion but is in line with the majority opinion.) Additionally Henes v. Morrissey held that a detained person not providing their name isn't on its own a violation of 946.41 Resisting or obstructing officer as the act of not identifying one's self