United States v. Mendenhall

Supreme Court of United States
446 U.S. 544 (1980)

ELI5:

Rule of Law:

A person is 'seized' within the meaning of the Fourth Amendment only if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that they were not free to leave.

Facts:

Sylvia Mendenhall arrived at Detroit Metropolitan Airport on a flight from Los Angeles.
Two Drug Enforcement Administration (DEA) agents observed Mendenhall be the last person to deplane, appear nervous, scan the area, and walk past the baggage claim without luggage.
The agents approached Mendenhall in the airport concourse, identified themselves as federal agents, and asked to see her identification and airline ticket.
Mendenhall produced a driver's license in her name and an airline ticket in the name of 'Annette Ford.'
After the agents returned her license and ticket, they asked if she would accompany them to the airport DEA office for further questions, and she did so.
In the DEA office, agents told Mendenhall she had the right to decline a search of her person and handbag, to which she responded, 'Go ahead.'
A female police officer arrived, again asked Mendenhall for consent to search her person, and Mendenhall replied that she did.
During the search, Mendenhall removed two small packages containing heroin from her undergarments and handed them to the policewoman, at which point she was arrested.

Procedural Posture:

Sylvia Mendenhall was charged with possessing heroin with intent to distribute in the U.S. District Court for the Eastern District of Michigan.
Mendenhall filed a motion to suppress the heroin evidence, arguing it was the fruit of an unconstitutional search and seizure.
The District Court, as the court of first instance, denied the motion to suppress.
Following a trial on stipulated facts, Mendenhall was convicted.
Mendenhall, as appellant, appealed her conviction to the U.S. Court of Appeals for the Sixth Circuit.
A panel of the Court of Appeals reversed the conviction, finding the search was unlawful.
The Court of Appeals granted a rehearing en banc and reaffirmed its panel's decision to reverse.
The United States, as petitioner, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does a consensual encounter between law enforcement and a citizen in a public place constitute a 'seizure' under the Fourth Amendment if a reasonable person under the circumstances would have believed they were free to decline the requests and walk away?

Opinions:

Majority - Justice Stewart

No, such an encounter does not constitute a seizure. A person has been 'seized' within the meaning of the Fourth Amendment only if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave. Here, the agents did not restrain Mendenhall's liberty by means of physical force or a show of authority. The events took place in a public concourse, the agents wore no uniforms, displayed no weapons, and did not demand to see her identification, but rather requested it. Nothing in the record suggests Mendenhall had any objective reason to believe she was not free to end the conversation and walk away. Because the initial encounter was not a seizure, her subsequent consent to accompany the agents to their office and to the search was voluntary and not tainted by any prior unconstitutional conduct.

Concurring - Justice Powell

This opinion assumes, for the sake of argument, that the initial stop was a seizure. Even under that assumption, the agents' actions were constitutional because they had reasonable suspicion that Mendenhall was engaging in criminal activity, justifying an investigative stop under Terry v. Ohio. The agents, relying on their experience, observed conduct consistent with a 'drug courier profile,' including arriving from a source city, being the last to deplane, appearing nervous, and not claiming luggage. Given the compelling public interest in detecting drug trafficking and the minimal nature of the intrusion, the agents' reasonable suspicion made the stop lawful.

Dissenting - Justice White

Yes, the encounter was a seizure that required reasonable suspicion. It is undisputed that Mendenhall was not free to leave after the DEA agents stopped her and inspected her identification. A reasonable person would not feel free to walk away when confronted by federal agents who take possession of their ticket and license. The facts observed by the agents were consistent with innocent behavior and did not amount to the reasonable suspicion required to justify the seizure. Furthermore, escorting Mendenhall to the DEA office was functionally an arrest requiring probable cause, which was absent. Her subsequent consent was not voluntary but was mere acquiescence to an unconstitutional show of authority.

Analysis:

This case is significant for establishing the objective 'free to leave' test to determine whether a police-citizen encounter constitutes a Fourth Amendment 'seizure.' By creating a clear distinction between a consensual encounter and a seizure, the ruling allows law enforcement to approach and question individuals in public without any level of suspicion, as long as the interaction does not convey that compliance is required. The fractured nature of the decision, with only a plurality endorsing the 'no seizure' rationale, initially left the test's precedential weight unclear, but it was later adopted by a majority of the Court and remains a cornerstone of Fourth Amendment seizure analysis.

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