The following excerpt is from Dancy v. McGinley, 843 F.3d 93 (2nd Cir. 2016):
Intent is a factorto a limited extent. A plaintiff must prove that an officer intended to commit acts that constituted a seizure in the first instance. The Fourth Amendment is not implicated absent a "governmental termination of freedom of movement through means intentionally applied ." Brower v. Cty. of Inyo , 489 U.S. 593, 59697, 109 S.Ct. 1378, 103 L.Ed.2d 628 (1989) ("[That] the detention ... be willful.... is implicit in the word seizure, which can hardly be applied to an unknowing act."). But as long as an officer deliberately performed acts that constitute a seizure, the Fourth Amendment has been triggered, regardless of whether it was accomplished by the exact method intended.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.