State v. Icard

WYNN, Judge.

In determining whether Fourth Amendment protections apply to a search or seizure by the police, we consider whether, under the totality of the circumstances, a reasonable person would have felt that she was not free to decline the police request or otherwise ter*79mínate the encounter with them.1 Here, because we find that a reasonable person in Defendant Lori Shannon Icard’s position would not have felt “free to . . . terminate the encounter” with the police, we hold that the police search of her purse was governed by the Fourth Amendment. However, noting that Defendant also…