United States v. Easley, 911 F.3d 1074 (10th Cir. Dec. 26, 2018)

The defendant raised a Fourth Amendment challenge asserting she had been seized because a reasonable person in her situation would not have felt free to end the encounter with the police and leave, especially when factoring in her subjective characteristics such as race.  In rejecting the adoption of a subjective analysis, the Tenth Circuit reaffirmed that the test for a Fourth Amendment seizure is objective, and the addition of subjective characteristics would unnecessarily complicate the application of the law.