to attempt a robbery. The case hinged on whether the weapons were admissible as evidence under the Fourth Amendment, which protects against unreasonable and warrantless searches and seizures, and prevents evidence collected in such a manner from being used in court. The opinion of the Court was that in lieu of the circumstances, in which the officer had reason to fear for his own safety, the pat-down was reasonable and did not constitute a search to which the Fourth Amendment is applicable. Specifically, the Court held that “Though the police must, whenever practicable, secure a warrant to make a search and seizure, that procedure cannot be followed where swift action based upon on-the-spot observations of the officer on the beat is required” and “The reasonableness of any particular search and seizure must be assessed in light of the particular circumstances against the standard of whether a man of reasonable caution is warranted in believing that the action taken was appropriate.” While these particular circumstances warranted a search based on the safety of the officer, the decision of the Court allowed for a greater freedom of officers to confront and question individuals in other situations. The Supreme Court has frequently referenced Terry v. Ohio and the principle of “mere questioning” in later cases, including INS v. Delgado. The most important formulation of the principle as it relates to Delgado is that “law enforcement officials can approach and speak to individuals without the constraints of the Fourth Amendment’s reasonableness standard, so long as the encounter is consensual.” United States v. Mendenhall Terry v. Ohio, and the ensuing principle of mere questioning, left open the important question of where the line is drawn between a consensual encounter and a temporary detention. In United States v. Mendenhall, the Court outlined a number of variables which may indicate a temporary detention or seizure, and a number of variables which may indicate a mere consensual stop. Those indicative of a seizure are “(1) threatening presence of several officers; (2) display of weapons by officer; (3) some physical touching of the individual; and (4) use of language or tone of voice indicating that compliance with the request might be compelled.” Those factors indicative of a consensual stop are “(1) questioning in public; (2) officers not wearing uniforms; (3) displaying no weapons; (4) approaching, not summoning, an individual and identifying oneself as a law enforcement official; and (5)