that the seizure was based on reasonable suspicion of criminal activity. 1 . The Fourth Amendment applies to the States through the Fourteenth Amendment. Mapp v. Ohio, 367 U.S. 643, 655, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961). 2 . Justice Clark acknowledges that repeating this inaccurate premise in dicta in Day was also error. 3 . This observation is hardly unique to Williams. See, e.g., Donaldson, 380 S.W.3d at 92 ("[I]n the context of traffic stops, the protections afforded by article I, section 7 of the Tennessee Constitution [are] coextensive with the protections afforded by the Fourth Amendment.”); Binette, 33 S.W.3d at 218; Vineyard, 958 S.W.2d at 733; Sneed, 221 Tenn. at 13, 423 S.W.2d at 860. 4 . See State v. Walters, 1997-NMCA-013, ¶ 22, 123 N.M. 88, 934 P.2d 282, 288 (1996) (<HOLDING>). 5 . See People v. Dittmar, 352 Ill.Dec. 403,
holding flashing police lights convey message that car occupants not free to leave holding that the driver of a car who had permission to use the car had standing to challenge its search recognizing that emergency lights convey a signal that an officer approaching a car at night presents no threat to the occupant of the car holding that there was reasonable suspicion to stop an occupant of a parked car based on his presence late at night in an area known for drug activity his leaning over the car console with a faint light and his attempt to hide something upon seeing a police officer holding that each occupant of a car has a right to challenge the propriety of a traffic stop under the fourth amendment