Warrantless police-citizen encounters have long perplexed reviewing courts. Was the encounter unreasonable? If so, was the encounter justifiable? Reasonableness, of course, is the touchstone of the Fourth Amendment.Virtually all police-citizen encounters involve some level of “seizure,” though some encounters, because they are reasonable, do not implicate the Fourth Amendment. Others, though unreasonable, may be otherwise justified (yes, even sans warrant).A recent 4th District Appellate Court opinion by …