People of Michigan v. Matthew Scott Duff

Summary

The Michigan Supreme Court held that defendant was seized under the Fourth Amendment when officers partially obstructed his vehicle, illuminated it with headlights and a spotlight, and approached from both sides in an isolated parking lot at night. The Court rejected a complete-blockage requirement and held that seizure must be determined under the totality of the circumstances. It reversed and remanded for the Court of Appeals to decide whether the officer had reasonable suspicion when the seizure occurred and, if not, whether the exclusionary rule applies.