Police block a person’s car in a narrow parking lot. Was this a seizure under 4th Amendment?

A Fourth Amendment seizure occurs “when physical force is used to restrain movement or when a person submits to an officer’s ‘show of authority.’ ” United States v. Brodie , 742 F.3d 1058, 1061 (D.C. Cir. 2014) (quoting California v. Hodari D. , 499 U.S. 621, 626, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991) ). A show of authority sufficient to constitute a seizure occurs where “the police conduct would have communicated to a reasonable person that he was not at liberty to ignore the police presence and go about his business,” Florida v. Bostick , 501 U.S. 429, 437, 111 S.Ct. 2382, 115 L.Ed.2d 389 (1991) (internal quotation marks omitted), or, put another way, where “a reasonable person would have believed that he was not free to leave,” United States v. Mendenhall , 446 U.S. 544, 554, 100 S.Ct. 1870, 64 L.Ed.2d 497 (1980).

The officers’ conduct—pulling into the narrow parking lot at night; training the take-down light on the Jeep; and, most importantly, parking their cruiser within a few feet of the Jeep’s nose—amounted to a “show of authority” that “would have communicated to a reasonable person” in Delaney’s position “that he was not at liberty to ignore the police presence and go about his business.”

Read full case here: United States v. Delaney, 955 F.3d 1077, 1083 (D.C. Cir. 2020), https://casetext.com/case/united-states-v-delaney-18/