Case Citator › United States v. Mendenhall

United States v. Mendenhall

Is it still good law? What later courts have actually done to this case.

Questioned by some courts
Court
Supreme Court of the United States
Citation
446 U.S. 544
Decided
Confirmed treatments
1
Flagged citations read
93 of 94
Citing cases (total)
6,313
Treatment dates
2010
Questioned by some courts
At least one reviewed court has questioned this case’s reasoning or continued validity. No reviewed court has overruled it. United States v. Mendenhall is questioned: 93 of the 94 flagged citations have been read, the text of the other one could not be retrieved, and the confirmed treatment is listed below. The nonprecedential Third Circuit opinion in United States v. Erick Coleman questioned whether Mendenhall's free-to-leave formulation remained sufficient after California v. Hodari D. absent physical force or submission to authority.
More on how this was screened

The other opinions read applied Mendenhall, reaffirmed its objective seizure framework, rejected an argument to abandon a Mendenhall-based rule, or placed adverse language on unrelated authorities, trial rulings, and history parentheticals.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

6,313 later cases cite United States v. Mendenhall; 94 of those citations sat close to treatment language and were flagged for reading; 93 of them have been read, and the text of 1 citing opinion could not be retrieved, so it remains unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Mendenhall?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Questioned

  • The Third Circuit questioned whether Mendenhall's reasonable-person, free-to-leave test remained sufficient to establish a seizure without physical restraint or submission to a show of authority.

    United States v. Erick Coleman · Third Circuit · filed

    In United States v. Mendenhall, the Supreme Court determined “a person has been ‘seized’ within the meaning of the Fourth Amendment only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave.” 446 U.S. 544, 554 (1980). ... Our decision in United States v. Waterman, 569 F.3d 144 (3d Cir. 2009), and Supreme Court jurisprudence call into question whether a person can be “seized” for Fourth Amendment purposes when a reasonable person in the same circumstances would not feel free to terminate the encounter with law enforcement, without a law enforcement officer physically restraining the suspect or making a showing of authority to which the suspect submits.
    Read the full opinion on CourtListener →

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