United States v. Mendenhall
| United States v. Mendenhall | |
|---|---|
| Argued February 19, 1980 Decided May 27, 1980 | |
| Full case name | United States v. Sylvia Mendenhall |
| Citations | 446 U.S. 544 (more) 100 S. Ct. 1870; 64 L. Ed. 2d 497; 1980 U.S. LEXIS 102 |
| Argument | [ Oral argument] |
| Case history | |
| Prior | 596 F.2d 706 (6th Cir. 1979); cert. granted, 444 U.S. 822 (1979). |
| Subsequent | Rehearing denied, 448 U.S. 908 (1980). |
| Holding | |
| A person is "seized" within the meaning of the Fourth Amendment if a "reasonable person" in the same position "would have believed that he was not free to leave." This test must be viewed under the totality of the circumstances. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Stewart (parts I, II-B, II-C, III), joined by Burger, Blackmun, Powell, Rehnquist |
| Concurrence | Stewart (part II-A), joined by Rehnquist |
| Concurrence | Powell, joined by Burger, Blackmun |
| Dissent | White, joined by Brennan, Marshall, Stevens |
| Laws applied | |
| U.S. Const. amend. IV | |
United States v. Mendenhall, 446 U.S. 544 (1980), was a United States Supreme Court case that determined "seizure" occurs when an officer uses displays of authority to detain a person.
The United States Court of Appeals for the Sixth Circuit heard the appeal of Ms. Sylvia Mendenhall as pertaining to Ms. Mendenhall's alleged unconstitutional seizure by two DEA agents at Detroit Metropolitan Airport. The court ruled against the defendant in a 5–4 majority, though the court's Dissent shows confusion as to the majority vote.
The decision notably set a standard by which a valid consensual stop could be converted into an unconstitutional Terry stop, such as by "the threatening presence of several officers, the display of a weapon by an officer, some physical touching of the person of the citizen, or the use of language or tone of voice indicating that compliance with the officer's request might be compelled."