Prior to "Hodari," the Supreme Court held that an individual can be seized either by physical restraint or a show of authority. The standard developed to determine whether or not a seizure had occurred was whether, given all the circumstances, a reasonable person would have felt free to leave. Under this test, if the police-citizen encounter was determined to have been a seizure, then the fourth amendment and its constitutionally guaranteed protections applied. In California v. Hodari D., however, the Court departed from the "reasonable person" test and held that a police-citizen encounter amounted to a seizure only if the suspect, when faced with a show of authority, yielded to that show of authority. In essence, the Court concluded that a reasonable person, faced with an unreasonable show of authority, must always yield to that show of authority so as to be guaranteed constitutional protections. In analyzing this decision, this note traces the origins of the fourth amendment and the Supreme Court's previous holdings regarding seizures, including the "reasonable person" test. It then examines the facts, procedural history, and decision in Hodari, followed by a scrutiny of the holding to demonstrate the inconsistencies with previous Supreme Court decisions. The note concludes with a discussion of the practical impact of the Hodari decision upon future police- citizen encounters. 224 footnotes