In Brendlin v. California, 551 U.S. 249 (2007), the Supreme Court held that a passenger in a lawfully stopped vehicle is just as “seized” under the Fourth Amendment as the driver. When police activate their lights and a vehicle stops, neither the driver nor any passenger is free to leave until the stop concludes. The Court reasoned that a reasonable passenger would not feel free to exit or otherwise terminate the encounter because the officer’s show of authority effectively restrains everyone in