CA6: Def’s failure to submit to officer’s show of authority showed it was not a seizure

“The United States appeals the district court’s order suppressing a firearm found in defendant Samuel Johnson’s car during a traffic stop. The district court ruled that because the police had unconstitutionally seized Johnson before he rolled through a stop sign, this traffic violation could not justify the stop. Considering all the facts and circumstances, we conclude that Johnson’s actions did not objectively demonstrate that he had submitted to police authority before he ran the stop sign, and he therefore was not seized before this violation. Accordingly, we reverse.” United States v. Johnson, 2015 U.S. App. LEXIS 20614 (6th Cir. Nov. 23, 2015).