Perhaps there is something about the final stages of their careers that causes people to resolve conflicts by reconciling the seemingly irreconcilable. Albert Einstein spent the last days of his career searching for a unified field theory that would eliminate the contradictory laws governing relativity and quantum mechanics. Stephen Hawking has taken up this quest which has been renamed a search for the Theory of Everything. On a “slightly” more modest level, I find the later stages of my career drawing me toward formulating a unified theory governing seizures of the person. The challenge is to blend three different tests the Supreme Court has applied when defining a Fourth Amendment seizure. These tests were articulated, over a period of eleven years, in United States v. Mendenhall, Brower v. County of Inyo, and California v. Hodari D. Before addressing those cases, however, we must begin at the beginning with an examination of Terry v. Ohio. Not to belabor the references to physics, but Terry is the big bang that starts the modern world of variable levels of seizures of the person.

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