What constitutes a detention rather than an arrest?

A detention is less intrusive than an arrest, and requires a lesser standard of "reasonable suspicion" of unlawful activity for officers to detain lawfully. Washington v. Lambert, 98 F.3d 1181, 1185 (9th Cir.1996). A detention is often indicated by less aggressive tactics and less force used by officers. Id. Additionally, if the suspects are uncooperative, an officer's behavior will more likely constitute a detention rather than an arrest. Allen v. City of Los Angeles, 66 F.3d 1052, 1057 (9th Cir.1995) (holding that a driver's high speed and refusal to pull over constituted enough resistance to establish officer conduct as a detention, only requiring reasonable

[135 F.Supp.3d 1159]

suspicion for the officers to lawfully detain).