MI: Partially blocking a car can be a seizure, here without RS

“A seizure may occur when a police vehicle partially blocks a defendant’s egress if the totality of the circumstances indicate that a reasonable person would not have felt free to leave; while the position of the police vehicle is an important consideration to how a reasonable person would evaluate the encounter, courts must also consider the remainder of the police conduct during the encounter to evaluate whether a seizure has occurred. Additional considerations in evaluating the totality of the circumstances include whether the police clearly meant to initiate contact with the defendant and any relevant social expectations, both of which may make a reasonable person feel they were not free to leave. The judgment of the Court of Appeals was reversed because the totality of the circumstances established that defendant was seized before the officers observed signs of intoxication. The case was remanded to the Court of Appeals to determine whether Deputy Jason Pence had reasonable suspicion of criminal conduct when defendant was initially seized. To the extent the Court of Appeals decision in People v Anthony, 327 Mich App 24; 932 N.W.2d 202 (2019), established a bright-line test that a person’s car is seized only if their car is completely blocked in by law enforcement, that decision was overruled as inconsistent with consideration of the totality of the circumstances.” People v. Duff, 2024 Mich. LEXIS 1435 (July 26, 2024) (from the syllabus).