Does Police Officer's Show of Authority Constitute An Illegal Seizure If It Is Not Supported by Reasonable Objective Grounds ?

In People v. Brownlee, 186 Ill. 2d 501, 713 N.E.2d 556, 239 Ill. Dec. 25 (1999), the supreme court followed these principles and emphasized that an individual may not be lawfully seized absent reasonable, objective grounds supporting the seizure. Brownlee, 186 Ill. 2d 501, 713 N.E.2d 556, 239 Ill. Dec. 25. In Brownlee, two officers flanked the front doors of a vehicle after a traffic stop ended, said nothing for approximately two minutes, then requested consent to search the vehicle despite having no probable cause or reasonable suspicion of criminal activity to detain the vehicle's occupants. Brownlee, 186 Ill. 2d 501, 713 N.E.2d 556, 239 Ill. Dec. 25. In such a situation, our supreme court found that a reasonable individual in the occupants' situation would not feel free to leave and held that the officers' show of authority constituted an illegal seizure. Brownlee, 186 Ill. 2d 501, 713 N.E.2d 556, 239 Ill. Dec. 25.