In Golphin v. State, this Court rejected the holding of the Fourth District Court of Appeal in Baez v. State, 814 So. 2d 1149 (Fla. 4th DCA 2002). The Fourth District had concluded that as a matter of law, an otherwise consensual encounter matures into a seizure when an officer retains a person's identification to conduct a check for outstanding warrants. See Golphin, 945 So. 2d at 1174. In Golphin v. State, 838 So. 2d 705 (Fla. 5th DCA 2003), the Fifth District had rejected the appellant's contention, based on Baez, that he was unlawfully seized at the moment an officer retained his identification. Instead, the Fifth District explained that per se rules were inappropriate under Bostick v. State, 554 So. 2d 1153, 1154 (Fla. 1989), held that Golphin had not been seized under the totality of the circumstances, and certified conflict with Baez. Golphin, 838 So. 2d at 706-08. On appeal, this Court approved the decision of the Fifth District, Golphin, 945 So. 2d at 1193, explaining that the determination "does not turn solely on any one factor, but must be informed by the total circumstances of the officers' approach, their comportment, Golphin's reaction, and the circumstances surrounding the request for identification as well as the subsequent warrants check." Id. at 1184. More recently, in G.M., this Court rejected a petitioner's contention that the activation of police lights always constitutes a seizure, emphasizing that "the activation of police lights is one important factor to be considered in a totality-based analysis as to whether a seizure has occurred." 19 So. 3d at 979.