Mendenhall test (Washington) · Go Syfert
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Mendenhall test in Washington

12 Washington opinions name it 2 courts 1997–2019 0 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
State v. Younggreen
wash · 1998 · cited in 5 Washington opinions naming this issue, 2004–2019
2 sentences

2019State v. Young, 135 Wn.2d 498 , 957 P.2d 681 (1998).

2019State v. Young, 135 Wn.2d 498 , 957 P.2d 681 (1998).

25
United States v. James Buchanon (94-3551), William Reed, Jr. (94-3660)green
ca6 · 1995 · cited in 2 Washington opinions naming this issue, 2009–2009
2 sentences

2009Dec. 519 (2009) (applying Mendenhall factors, the Appellate Court of Illinois concluded three officers standing next to suspect did not constitute a seizure); United States v. Jones, 523 F.3d 1235, 1237, 1242 (10th Cir. 2008) (no seizure when one officer spoke with suspect while three other officers hovered nearby); United States v. Buchanon, 72 F.3d 1217, 1224 (6th Cir. 1995) (arrival of three additional officers, with emergency lights blazing, minutes after initial traffic stop was a threatening presence, but without additional Mendenhall factors the threatening presence alone could not crea

2009App.3d 822 , 909 N.E.2d 232, 243 , 330 Ill.Dec. 519 (2009) (applying Mendenhall factors, the Appellate Court of Illinois concluded three officers standing next to suspect did not constitute a seizure); United States v. Jones, 523 F.3d 1235, 1237, 1242 (10th Cir.2008) (no seizure when one officer spoke with suspect while three other officers hovered nearby); United States v. Buchanon, 72 F.3d 1217, 1224 (6th Cir.1995) (arrival of three additional officers, with emergency lights blazing, minutes after initial traffic stop was a threatening presence, but without additional Mendenhall factors the

22
United States v. Jonesgreen
ca10 · 2008 · cited in 2 Washington opinions naming this issue, 2009–2009
2 sentences

2009Dec. 519 (2009) (applying Mendenhall factors, the Appellate Court of Illinois concluded three officers standing next to suspect did not constitute a seizure); United States v. Jones, 523 F.3d 1235, 1237, 1242 (10th Cir. 2008) (no seizure when one officer spoke with suspect while three other officers hovered nearby); United States v. Buchanon, 72 F.3d 1217, 1224 (6th Cir. 1995) (arrival of three additional officers, with emergency lights blazing, minutes after initial traffic stop was a threatening presence, but without additional Mendenhall factors the threatening presence alone could not crea

2009App.3d 822 , 909 N.E.2d 232, 243 , 330 Ill.Dec. 519 (2009) (applying Mendenhall factors, the Appellate Court of Illinois concluded three officers standing next to suspect did not constitute a seizure); United States v. Jones, 523 F.3d 1235, 1237, 1242 (10th Cir.2008) (no seizure when one officer spoke with suspect while three other officers hovered nearby); United States v. Buchanon, 72 F.3d 1217, 1224 (6th Cir.1995) (arrival of three additional officers, with emergency lights blazing, minutes after initial traffic stop was a threatening presence, but without additional Mendenhall factors the

22
State v. Larsongreen
wash · 1980 · cited in 2 Washington opinions naming this issue, 2004–2004
2 sentences

2004See id. at 640 ; O’Neill, 148 Wn.2d at 580 n.4.

2004See id. at 640 ; O’Neill, 148 Wn.2d at 580 n.4.

22
State v. Younggreen
wash · 1998 · cited in 3 Washington opinions naming this issue, 2014–2019
2 sentences

2019State v. Young, 135 Wn.2d 498 , 957 P.2d 681 (1998).

2019State v. Young, 135 Wn.2d 498 , 957 P.2d 681 (1998).

13

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
United States v. Mendenhall green
scotus · 1980
2 sentences

2018Under the Mendenhall test for determining whether a seizure occurred, “‘[N]ot every encounter between a police officer and a citizen is an intrusion requiring an objective justification.’” Rankin, 151 Wn.2d at 695 (quoting Mendenhall, 446 U.S. at 553 ).

2018Under the Mendenhall test for determining whether a seizure occurred, “‘[N]ot every encounter between a police officer and a citizen is an intrusion requiring an objective justification.’” Rankin, 151 Wn.2d at 695 (quoting Mendenhall, 446 U.S. at 553 ).

32004–2018
State v. Stroud green
washctapp · 1981
2 sentences

2018There is a 'seizure' when, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave." State v. Stroud, 30 Wn.

2018There is a 'seizure' when, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave." State v. Stroud, 30 Wn.

22017–2018
State v. Rankin green
wash · 2004
2 sentences

2018Under the Mendenhall test for determining whether a seizure occurred, “‘[N]ot every encounter between a police officer and a citizen is an intrusion requiring an objective justification.’” Rankin, 151 Wn.2d at 695 (quoting Mendenhall, 446 U.S. at 553 ).

2018Under the Mendenhall test for determining whether a seizure occurred, “‘[N]ot every encounter between a police officer and a citizen is an intrusion requiring an objective justification.’” Rankin, 151 Wn.2d at 695 (quoting Mendenhall, 446 U.S. at 553 ).

12018–2018
State v. Nettles green
washctapp · 1993
2 sentences

2013Although Morris's partner was present in the transit tunnel, it is undisputed that DR saw only Morris at the time of the 9 For example, no seizure occurred when an officer parked her patrol car, exited, and called out to a group of men, "'Gentlemen, I'd like to speak with you, could you come to my car?'" Nettles, 70 Wn.

2013Although Morris's partner was present in the transit tunnel, it is undisputed that DR saw only Morris at the time of the 9 For example, no seizure occurred when an officer parked her patrol car, exited, and called out to a group of men, "'Gentlemen, I'd like to speak with you, could you come to my car?'" Nettles, 70 Wn.

12013–2013
People v. Robinson green
illappct · 2009
2 sentences

2009App.3d 822 , 909 N.E.2d 232, 243 , 330 Ill.Dec. 519 (2009) (applying Mendenhall factors, the Appellate Court of Illinois concluded three officers standing next to suspect did not constitute a seizure); United States v. Jones, 523 F.3d 1235, 1237, 1242 (10th Cir.2008) (no seizure when one officer spoke with suspect while three other officers hovered nearby); United States v. Buchanon, 72 F.3d 1217, 1224 (6th Cir.1995) (arrival of three additional officers, with emergency lights blazing, minutes after initial traffic stop was a threatening presence, but without additional Mendenhall factors the

2009App.3d 822 , 909 N.E.2d 232, 243 , 330 Ill.Dec. 519 (2009) (applying Mendenhall factors, the Appellate Court of Illinois concluded three officers standing next to suspect did not constitute a seizure); United States v. Jones, 523 F.3d 1235, 1237, 1242 (10th Cir.2008) (no seizure when one officer spoke with suspect while three other officers hovered nearby); United States v. Buchanon, 72 F.3d 1217, 1224 (6th Cir.1995) (arrival of three additional officers, with emergency lights blazing, minutes after initial traffic stop was a threatening presence, but without additional Mendenhall factors the

12009–2009
State v. O'Neill green
wash · 2003
2 sentences

2004See id. at 640 ; O’Neill, 148 Wn.2d at 580 n.4.

2004See id. at 640 ; O’Neill, 148 Wn.2d at 580 n.4.

12004–2004
State v. O'NEILL green
wash · 2003
2 sentences

2004See id. at 640, 611 P.2d 771 ; O'Neill, 148 Wash.2d at 580 n. 4, 62 P.3d 489 .

2004See id. at 640, 611 P.2d 771 ; O'Neill, 148 Wash.2d at 580 n. 4, 62 P.3d 489 .

12004–2004
California v. Hodari D. green
scotus · 1991
2 sentences

1997The Mendenhall analysis above, however, establishes "a necessary, but not a sufficient, condition for seizure.” California v. Hodari D., 499 U.S. 621, 628 , 111 S. Ct. 1547 , 113 L.

1997The Mendenhall analysis above, however, establishes "a necessary, but not a sufficient, condition for seizure.” California v. Hodari D., 499 U.S. 621, 628 , 111 S. Ct. 1547 , 113 L.

11997–1997

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 77 (1988–2023) WA 12 (1997–2019) PA 12 (1992–2018) TX 10 (1993–2022) CA 8 (1983–2021) OH 8 (1989–2025) VA 8 (1992–2012) WI 7 (2002–2024) MT 7 (1894–2024) TN 5 (1999–2019) NC 5 (1995–2018) MA 5 (2001–2015) NM 4 (2009–2015) FL 4 (2009–2012) LA 4 (1989–2009) MD 4 (1991–2019) NH 3 (1988–2004) MO 3 (1991–2016) DC 2 (1999–2019) HI 2 (1992–2011) NE 2 (1991–1992) CT 2 (1993–2008) KY 2 (2025–2026) WY 2 (1993–1994) ID 2 (1991–1995)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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