California, United States of America
The following excerpt is from People v. Zapien, H039878 (Cal. App. 2014):
the vehicle's occupants were not free to leave. (See California v. Hodari D. (1991) 499 U.S. 621, 628.) The vehicle driver remained in the car after stopping in the driveway, consistent with a submission to the show of police authority. (See Brendlin, supra, 551 U.S. at p. 255 ["passive acquiescence" can show that a seizure occurred in response to a show of authority if " 'in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave' "].) Moreover, defendant himself submitted to that show of authority. Although he exited the vehicle and looked around, he remained standing in the passenger doorway after seeing the police, instead of proceeding to a further destination.
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