context: Here, the police presented a clear show of authority when they approached Lowe. The only issue is whether (and when) Lowe submitted to that authority.
citation_a.signal: see also
citation_a.parenthetical: "But what may amount to submission depends on what a person was doing before the show of authority: a fleeing man is not seized until he is physically overpowered, but one sitting in a chair may submit to authority by not getting up to run away."
citation_a.sentence: See Johnson v. Campbell, 332 F.3d 199, 206 (3d Cir.2003) (concluding seizure occurred when individual remained in his vehicle yet refused to comply with an officer’s orders to roll down the window); see also Brend- lin v. California, 551 U.S. 249, 262, 127 S.Ct. 2400, 168 L.Ed.2d 132 (2007) (“But what may amount to submission depends on what a person was doing before the show of authority: a fleeing man is not seized until he is physically overpowered, but one sitting in a chair may submit to authority by not getting up to run away.”); United States v. Johnson, 620 F.3d 685, 691 (6th Cir.2010) (“It would be an unnatural reading of the case law to hold that a defendant who is ordered to stop is not seized until he stops and complies with a subsequent order to raise his hands.” (emphasis in original)).
citation_b.signal: see
citation_b.identifier: 499 U.S. 621, 626
citation_b.parenthetical: explaining that a seizure is effected when a suspect evinces submission to a "show of authority"
citation_b.sentence: See California v. Hodari D., 499 U.S. 621, 626, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991) (explaining that a seizure is effected when a suspect evinces submission to a “show of authority”). Remaining in place in response to an officer’s show of authority can alone be sufficient for submission.