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J.P., a Juvenile, Appellant, v. STATE of Florida, Appellee.
Affirmed. See § 843.02, Fla. Stat. (2026) (“Whoever shall resist, obstruct, or oppose any officer ․ legally authorized to execute process in the execution of legal process or in the lawful execution of any legal duty, without offering or doing violence to the person of the officer, shall be guilty of a misdemeanor of the first degree[.]”); Baptiste v. State, 995 So. 2d 285, 295 (Fla. 2008) (“We conclude that a person has been ‘seized’ within the meaning of the Fourth Amendment only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave.”); State v. D.F., 92 So. 3d 216, 218 (Fla. 3d DCA 2011) (“The determination whether a seizure has occurred by a show of authority requires the application of an objective test, and not whether the citizen perceived that he was being ordered to restrict his movement. This objective standard is not concerned with the officers’ subjective intent, but with what the officers’ words and actions would have conveyed to a reasonable, innocent person.” (internal quotation marks omitted) (first quoting California v. Hodari D., 499 U.S. 621, 628, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991); and then quoting Caldwell v. State, 41 So. 3d 188, 195–97 (Fla. 2010))); United States v. Mendenhall, 446 U.S. 544, 554, 100 S.Ct. 1870, 64 L.Ed.2d 497 (1980) (holding “the use of language or tone of voice indicating that compliance with the officer's request might be compelled” is indicative of a seizure); J.C. v. State, 15 So. 3d 870, 872 (Fla. 2d DCA 2009) (“We conclude that a reasonable person would not feel free to walk away but rather would feel compelled to comply with a police officer's command, ‘I've got to talk to you for a minute. Hang on.’ ”); Neeley v. State, 112 So. 3d 764, 766 (Fla. 2d DCA 2013) (finding “ ‘stand by’ was a detention because a reasonable person under the circumstances would not feel free to leave or to disregard the instruction”); Popple v. State, 626 So. 2d 185, 188 (Fla. 1993) (finding an officer's directive restraining freedom of movement “constituted a show of authority” irrespective of “[w]hether characterized as a request or order”—“because a reasonable person under the circumstances would believe that he should comply”).
PER CURIAM.
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Docket No: No. 3D26-0845
Decided: October 15, 2026
Court: District Court of Appeal of Florida, Third District.
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