On review of the denial of a motion to suppress, what is the test for a search and seizure?

On review of the denial of a motion to suppress, we defer to the trial court's factual findings, where supported by substantial evidence, but exercise our independent judgment to determine whether, on the facts found, the search and seizure were reasonable under the Fourth Amendment. (People v. Camacho (2000) 23 Cal.4th 824, 830.)

Not every encounter between a police officer and an individual involves a seizure. A seizure occurs when the officer, "by means of physical force or show of authority," restrains the individual's freedom of movement. Whether a seizure has occurred is determined by an objective test that asks not whether the individual perceived that he was being ordered to restrict his movement, but whether the officer's words and actions would have conveyed that to a reasonable person. When police engage in conduct that would communicate to a reasonable person that he was not free to ignore the police presence and go about his business, there has been a seizure. (People v. Celis (2004) 33 Cal.4th 667, 673.)