The following excerpt is from United States v. Fiseku, 906 F.3d 65 (2nd Cir. 2018):
United States v. Newton , 369 F.3d 659, 674 (2d Cir. 2004). As we cautioned in Newton , "No one of these factors is determinative. But to satisfy the reasonableness standard, officers conducting stops on less than probable cause must employ the least intrusive means reasonably available to effect their legitimate investigative purposes." Id. (citation and internal quotation marks omitted).
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