May Police Officer Approach to Ask Questions Without Any Justification ?
Under both the federal and state constitutions, a seizure has occurred when a reasonable person would believe that he or she was not free to leave and that person has actually yielded to a show of authority or has been physically forced to yield. Id. at 236.
However, law enforcement officers are permitted to approach citizens, without any justification, to ask questions and even to request a consent to search. Id. at 235.
If a reasonable person would feel free "to disregard the police and go about his business," then this is an encounter which is consensual and merits no further analysis. Id., citing California v. Hodari D., 499 U.S. 621, 628, 111 S. Ct. 1547, 113 L. Ed. 2d 690, 698 (1991).