What is the test for determining whether a passenger of a vehicle was detained in a motor vehicle by police?

would have believed that he was not free to leave. Examples of circumstances that might indicate a seizure, even where the person did not attempt to leave, would be 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. [Citations.]" (United States v. Mendenhall (1980) 446 U.S. 544, 554-555, fn. omitted; cf. Brendlin v. California (2007) 551 U.S. 249, 261 [in determining whether a passenger of a vehicle was detained, "the issue is whether a reasonable passenger would have perceived that the show of authority was at least partly directed at him, and that he was thus not free to ignore the police presence and go about his business"].)

"The test is necessarily imprecise, because it is designed to assess the coercive effect of police conduct, taken as a whole, rather than to focus on particular details of that conduct in isolation. Moreover, what constitutes a restraint on liberty prompting a person to conclude that he is not free to 'leave' will vary, not only with the particular police conduct at issue, but also with the setting in which the conduct occurs. [Citations.]" (Michigan v. Chesternut (1988) 486 U.S. 567, 573-574 (Michigan).) It is an objective test. (See California v. Hodari D. (1991) 499 U.S. 621, 628; Michigan, supra, at p. 574.)