What constitutes a detention when a police officer says "stop" and the suspect does not actually stop?

California, United States of America


The following excerpt is from People v. Johnson, F060077, Kern Super. Ct. No. BF129298A (Cal. App. 2011):

However, a detention does not occur when a police officer says "stop" and the suspect does not actually stop. "A police officer may make a seizure by a show of authority and without the use of physical force, but there is no seizure without actual submission; otherwise, there is at most an attempted seizure, so far as the Fourth Amendment is concerned. [Citation.]" (Brendlin v. California (2007) 551 U.S. 249, 254, italics added.) When an officer orders a subject to halt in "a show of authority," and the

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