D.C.Cir.: Telling def to “chill out” not a seizure

“Officer Jones never made such a show of authority; he simply told Hagan, while in uniform and in a ‘conversational tone,’ to ‘chill out.’ … Jones neither told Hagan to stop nor asked him any questions. An approach by a uniformed police officer is not a seizure.” United States v. Hagan, No. 22-3089, 2024 U.S. App. LEXIS 7506 (D.C. Cir. Mar. 29, 2024).

The details from the CI and inferences from what was known and observations added up to probable cause. United States v. Yates, 2024 U.S. App. LEXIS 7443 (2d Cir. Mar. 29, 2024).*

The Quarles public safety exception can apply to statements taken at the police station after arrest. State v. Starr, 2024 Iowa Sup. LEXIS 33 (Mar. 29, 2024)* (quoting, inter alia, Trice v. United States, 662 A.2d 891, 893, 896 (D.C. 1995)).

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