The following excerpt is from USA v. Stephens, 206 F.3d 914 (9th Cir. 2000):
Police officers may not approach passengers on a bus, and request their consent to be questioned and searched if the officers "convey a message that compliance with their requests is required." Florida v. Bostick, 501 U.S. 429, 437 (1991). The test for whether a bus search is constitutional is not whether a reasonable person would feel "free to leave." Id. at 436. The test is whether, considering all of the circumstances, "a reasonable person would feel free to decline the officers' requests or otherwise terminate the encounter." Id. This is because "when a person is seated on a bus and has no desire to leave, the degree to which a reasonable person would feel that he or she could leave is not an accurate measure of the coercive effect of the encounter." Id.
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