What Is the Test to Determine Whether Individuals Interacting With Police Officers Are Under 'Investigative Detention' ?

In Commonwealth v. Sierra, 555 Pa. 170, 723 A.2d 644 (Pa. 1999), the Supreme Court recited the test to determine whether individuals interacting with police officers have been subjected to an "investigative detention." The test is whether, considering all the circumstances surrounding the encounter, the police conduct would communicate to a reasonable person that the person was not free to decline the officers' request or otherwise terminate the encounter. Id.