According to the Supreme Court in California v. Hodari D, involving a young man who threw away a rock of crack cocaine just before an officer physically apprehended him, a seizure occurs when an officer approaches someone with an intent to seize the person.

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The Supreme Court in California v. Hodari D ruled that a seizure under the Fourth Amendment occurs only when there is either physical force or submission to the assertion of authority, not merely when an officer approaches with intent to seize.

According to the Supreme Court in California V