What is the legal test for a search warrantless seizure?

examining the totality of the circumstances [citation], ..." ( People v. Robinson (2010) 47 Cal.4th 1104, 1120, 104 Cal.Rptr.3d 727, 224 P.3d 55.) The burden is on the prosecution to provide some justification for the warrantless search or seizure. ( People v. Williams (1999) 20 Cal.4th 119, 136, 83 Cal.Rptr.2d 275, 973 P.2d 52.)

Here, we are not concerned with a search, but instead, a seizure. A seizure is "far less intrusive than a search." ( United States v. Payton (9th Cir. 2009) 573 F.3d 859, 863 ( Payton ).) Whereas a search implicates a person's right to keep the contents of his or her belongings private, a seizure only affects their right to possess the particular item in question. (

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