United States v. Mendenhall
Supreme Court
446 U.S. 544 (1980)
Two plain-clothes DEA agents approached Mendenhall (defendant) in an airport after she exited her plane, believing her behavior matched patterns typical of drug couriers; she showed them her ticket and identification, which they returned, and after the agents identified themselves, she agreed to accompany them to their office, though one agent later testified she would have been restrained had she tried to leave at that point. At the office, she consented to a search of her bag and person, and agents discovered heroin hidden on her while she was undressing. The district court found her consent to search was voluntary, while the court of appeals held it was involuntary and tainted by prior government misconduct.
Whether a Fourth Amendment seizure has occurred where the totality of the circumstances indicates the citizen was free to leave police custody.