United States v. Mendenhall, 446 U.S. 544 (1980)

Facts

Mendenhall was walking through Detroit Metropolitan Airport when she was approached by narcotics agents.  After some questions, the agents asked if Mendenhall would come to the DEA office, which she did.  After entering the office, Mendenhall also allegedly consented to a search, where heroin was found on her.

Procedural History

The District Court denied the motion to suppress, finding that the initial approach of Mendenhall was permissible under Terry.  The Court of Appeals reversed, finding that the search was not consented, but a product of earlier official conduct violative of the Fourth Amendment.

Issue(s)

Did the District Court err in finding that the narcotics agents’ initial questioning of Mendenhall was permissible?

Holding(s)

No.

Reasoning/Analysis

The Court found that a person is seized only when, by means of physical force or show of authority, his freedom of movement is restrained.  As long as the person to whom questions are put remains free to disregard the questions and walk away, there has been no intrusion upon that person’s liberty or privacy.  On the facts of this case, no seizure of Mendenhall occurred.

Judgment/Outcome

The Court reversed the judgment of the Court of Appeals.