Police officer’s threat to arrest plaintiff for trespass if he didn’t leave a shopping center was not a Fourth Amendment seizure. Watkins v. Ramcharan, 2019 U.S. App. LEXIS 25016 (11th Cir. Aug. 22, 2019).
The officer’s encounter with a parked car and telling defendant to turn down the radio so they could talk was not a seizure. The DUI case failed, however, because the implied consent form was defective. City of Bismarck v. Vagts, 2019 ND 224, 2019 N.D. LEXIS 223 (Aug. 22, 2019).*