However, the Court has identified a constitutional difficulty with many modern vagrancy laws. In "Papachristou v. Jacksonville", , the Court held that a traditional vagrancy law was void for vagueness because its "broad scope and imprecise terms denied proper notice to potential offenders and permitted police officers to exercise unfettered discretion in the enforcement of the law." In "Brown v. Texas", , the Court struck down the application of Texas's stop-and-identify statute against Brown. They held that the Fourth Amendment requires reasonable suspicion to believe that an individual had committed, was committing, or was going to commit a crime before an individual can be required to identify himself, and that the presence of an individual in a known drug area cannot establish reasonable suspicion without more. And in "Kolender v. Lawson", , the Court struck down a California stop-and-identify law that required a suspect to provide "credible and reliable identification" upon request. The words "credible and reliable" were vague because they "provided no standard for determining what a suspect must do to comply with law, resulting in virtually unrestrained power to arrest and charge persons with a violation."