People v. Leach 

Officer stopped Defendant, then age 19, while he was walking late at night in a residential area, suspecting potential curfew violation. After officer returned his ID, offficer asked whether he could search Defendant, after Defendant told him that he had once been arrested in drug raid at his mother's house. Defendant consented, and search revealed cannabis on his person. Investigatory stop was concluded when Defendant's ID card was returned to him after a warrant check was done. As Mendenhall factors were absent, circumstances of stop are insufficient to find that a seizure occurred, as Defendant's consent was voluntary. (KNECHT, concurring; POPE, dissenting.)