rule from Mendenhall as follows; that "the threatening presence of several officers, the display of a weapon by an officer, some physical touching of the person of the citizen, or the use of language or tone of voice indicating that compliance with the officer's request might be compelled” is a threshold indication of a seizure taking place. Brennan concluded that the factory sweep was very much a seizure. While there was no restraint of the individuals physically, the sudden and systematic intrusion of 15 to 25 agents upon the factory and the manner in which they dealt with the workers demonstrated a “show of force” and created an “intimidating atmosphere” with “widespread disturbance among workers”, fit to indicate that a reasonable person would not feel free to leave, and that a seizure was in fact taking place. Notes External links United States Supreme Court cases United States Fourth Amendment case law 1984 in United States case law United States Supreme Court cases of the Burger Court Immigration case law