In Kolender v. Lawson, 461 U.S. 352 (1983), the United States Supreme Court reviewed the constitutionality of a California penal statute challenged as vague. "In evaluating a facial challenge to a state law, a federal court must, of course, consider any limiting construction that a state court or enforcement agency has proffered. Id. at 355. The Court looked at the construction of the statute by the lower California courts which had determined that, under the challenged terms of the statute, failure of an individual to provide "credible and reliable" identification permitted his arrest. Id. at 355-56. In striking down the challenged statute, the Supreme Court reasoned that the full discretion accorded to the police to determine whether the suspect has provided a "credible and reliable" identification necessarily "entrusts lawmaking to the moment-to-moment judgment of the policeman on his beat", and that it "encourages arbitrary enforcement by failing to describe with sufficient particularity what a suspect must do in order to satisfy the statute." Id. at 360-61. The Supreme Court found a statute that allowed law enforcement to require an individual to produce credible and reliable identification to account for their presence to be constitutionally infirm because it failed to establish minimal guidelines to govern enforcement of the statute since it left to each law enforcement officer the task of deciding what constituted "credible and reliable identification." ( Kolender v. Lawson, supra, 461 U.S. at p. 358.) The Court declared a California statute unconstitutional that made it illegal for a person to "loiter or wander upon the streets or from place to place without apparent reason or business and refuse to identify himself and to account for his presence when requested by any peace officer so to do, if the surrounding circumstances are such as to indicate to a reasonable man that the public safety demands such identification." Id. at 353. The court determined that the California law gave too much discretion to police. Specifically, the court stated, "an individual, whom sic police may think is suspicious but do not have probable cause to believe has committed a crime, is entitled to continue to walk the public streets 'only at the whim of any police officer' who happens to stop that individual." Id. The Court concluded that the statute was unconstitutionally vague because it encouraged arbitrary enforcement by "failing to describe with sufficient particularity what a suspect must do in order to" commit a violation. Id., at 361.