In California V

In California v.Hodari D.(1991) ,a juvenile dropped the drugs he was carrying before actually being 'seized' by police.What was the key issue in this case?

A) The prosecution said since the defendant was being pursued chased by the police,the chase itself constituted a 'seizure' under the Fourth Amendment.Thus charging them with possession of the drugs was legitimate.
B) That the recovery of the drugs was considered 'constructive possession.'
C) That the real issue was that officers had actually seen him throw the drugs away.
D) That he was 'not' actually seized under the Fourth Amendment until he had actually been subdued or submitted to the police,thus the drugs were not admissible.