In State v. Daniel, 12 S.W.3d 420, 428 (Tenn. 2000), the Tennessee Supreme Court, applying the Fourth Amendment's totality-of-the-circumstances test, so held without addressing whether the officer left the defendant's presence to run the warrants check.
The court directly addressed the dilemma faced by individuals placed in this situation:
"What begins as a consensual police-citizen encounter may mature into a seizure of the person. While many of the circumstances in this case point in the direction of a consensual police-citizen encounter, one circumstance reflects a distinct departure from the typical consensual encounter--Officer Wright's retention of Daniel's identification to run a computer warrants check. Without his identification, Daniel was effectively immobilized. Abandoning one's identification is simply not a practical or realistic option for a reasonable person in modern society. Contrary to the State's assertion, when an officer retains a person's identification for the purpose of running a computer check for outstanding warrants, no reasonable person would believe that he or she could simply terminate the encounter by asking the officer to return the identification." (12 S.W.3d at 427.)