What constitutes a detention under the Fourth Amendment?

Within the meaning of the Fourth Amendment, an individual is detained when police officers restrain his or her liberty by means of physical force or show of authority. (California v. Hodari D . (1991) 499 U.S. 621, 626, 111 S.Ct. 1547, 113 L.Ed.2d 690 ; United States v. Mendenhall (1980) 446 U.S. 544, 554, 100 S.Ct. 1870, 64 L.Ed.2d 497.) The test for whether a police officer's conduct amounts to a detention is whether the officer's conduct would indicate to a reasonable person that he or she is not free to leave, or otherwise to terminate the encounter. (United States v. Mendenhall , at p. 554, 100 S.Ct. 1870.)