Can a consensual encounter between a police officer and an individual avoid Fourth Amendment scrutiny?

Both parties agree that a consensual encounter would avoid Fourth Amendment scrutiny. "Unlike a detention, a consensual encounter between a police officer and an individual does not implicate the Fourth Amendment. . . . There is no Fourth Amendment violation as long as circumstances are such that a reasonable person would feel free to leave or end the encounter. [Citations.]" (People v. Rivera (2007) 41 Cal.4th 304, 309.) However, the parties disagree as to what standard should be used in determining whether appellant consented to leaving his house.