Key legal question
Whether uncooperative conduct in identity verification constitutes a special obstacle under Art. 13b(2) ANAG justifying prolongation of removal detention.
Extracted holding
Yes. False statements to a diplomat about not speaking English may amount to a special obstacle to enforcement and can justify prolongation of detention.
Extracted reasoning
The court treated deliberately uncooperative behavior during identity clarification as hindering execution of the removal order within the meaning of Art. 13b(2) ANAG.