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We note that “the subjective beliefs and intent of the officers are relevant” to the seizure analysis “only to the extent they have been conveyed to the person confronted.” United States v. Smith, 794 F.3d 681, 687 (7th Cir. 2015); see State v. Riley, 126 N.H. 257, 263 (1985).

3 Steeves, 158 N.H. at 675; see State v. Riley, 126 N.H. 257, 262-63 (1985).

He was outside, as opposed to being confined, for example, in a police cruiser.

So long as a reasonable person would feel free to leave, State v. Riley, 126 N.H. 257, 263-64 (1985), or to terminate the encounter, State v. McKeown, 151 N.H. 95, 97 (2004), the citizen is not seized under Part I, Article 19 of the State Constitution.

Booth’s subjective beliefs, however, are not determinative of the issue.

So long as a reasonable person would feel free to leave, State v. Riley, 126 N.H. 257, 262-63 (1985), or terminate the encounter, State v. McKeown, 151 N.H. 95, 97 (2004), the citizen is not seized under Part I, Article 19 of the State Constitution.

At the suppression hearing, defense counsel relied upon State v. Riley, 126 N.H. 257 (1985), and State v. Quezada, 141 N.H. 258 (1996), to argue that the seizure occurred when the detective ordered the defendant to stop.

Encounters that are purely voluntary or very brief do not generally constitute seizures.

Contained within this analysis “is a determination whether there has been a ‘show of authority’ such that the liberty of the individual has been restrained.” State v. Riley, 126 N.H. 257, 262, 490 A.2d 1362, 1366 (1985).

State v. Riley, 126 N.H. 257, 262, 490 A.2d 1362, 1366 (1985) (seizure occurs if there has been a “show of authority” in officer’s language or tone of voice).

Further, it is clear that the defendant was seized both at the moment he was stopped and while en route to the police station with the furniture, because “ ‘in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave.’” State v. Riley, 126 N.H. 257, 262, 490 A.2d 1362, 1366 (1985) (quoting United States v. Mendenhall, 446 U.S. 544, 554 (1980)).

We recognized this problem in State v. Riley, 126 N.H. 257, 490 A.2d 1362 (1985), when we adopted the objective standard for determining when a person is in custody: “If the subjective beliefs of the participants in the arrest are determinative of a finding of arrest, the determination turns on the mindset and, ultimately, the credibility of each.

A person is considered seized for purposes of part I, article 19 “‘if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave.’” State v. Riley, 126 N.H. 257, 262, 490 A.2d 1362, 1366 (1985) (quoting United States v. Mendenhall, 446 U.S. 544, 554 (1980) (opinion of Stewart, J.)); see Chaloux, 130 N.H. at 813, 546 A.2d at 1084 (stating that Riley adopted Mendenhall test to determine when a seizure has occurred under part I,

The standard for judging whether *258 a person has been seized for purposes of part I, article 19 of the New Hampshire Constitution is no less protective of our citizens’ rights.

Second, the defendant argues that he must have been arrested at the time he claims, since at that point “a reasonable person would have believed that he was not free to leave.” United States v. Mendenhall, 446 U.S. 544, 554 (1980); see State v. Riley, 126 N.H. 257, 263, 490 A.2d 1362, 1366 (1985) (adopting Mendenhall test to determine when a seizure of the person had occurred, within pt.

In State v. Riley, 126 N.H. 257, 263, 490 A.2d 1362, 1366 (1985), this court adopted the objective test articulated in United States v. Mendenhall, 446 U.S. 544 (1980), for the determination of whether a seizure has occurred.

“An individual is ‘seized’ for fourth amendment purposes ‘if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave.’ ” State v. Riley, 126 N.H. 257, 262, 490 A.2d 1362, 1366 (1985) (citing United States v. Mendenhall, 446 U.S. 544, 554 (1980) (opinion of Stewart, J.); Florida v. Royer, 460 U.S. 491, 502 (1983)).

An arrest is defined in RSA 594:1,1 (Supp. 1983) as “the taking of a person into custody in order that he may be forthcoming to answer for the commission of a crime.” The objective test for whether an arrest has occurred was articulated in United States v. Mendenhall, 446 U.S. 544 (1980), and adopted by this court in State v. Riley, 126 N.H. 257, 490 A.2d 1362 (1985): whether, “in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not f

In construing statutes we examine both the language and the *356 objective of the legislature.

In 1980, the United States Supreme Court held 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.” United States v. Mendenhall, 446 U.S. 544, 554 (1980) (opinion of Stewart, J.); see State v. Riley, 126 N.H. 257, 263, 490 A.2d 1362, 1366 (1985).

State v. Brodeur, 126 N.H. 411, 493 A.2d 1134 (1985); State v. Riley, 126 N.H. 257, 490 A.2d 1362 (1985).

State v. Riley, 126 N.H. 257, 262, 490 A.2d 1362, 1366 (1985); State v. Hamel, 123 N.H. 670, 676, 466 A.2d 555, 558 (1983); see Terry v. Ohio, 392 U.S. 1 (1968); see also Florida v. Royer, 460 U.S. 491, 502 (1983); United States v. Mendenhall, 446 U.S. 544, 554 (1980).