propose remedies). 35 . See 7/8/13 Defendants’ Proposed Remedial Relief (“Ligón Def. Rem.”). 36 . See Ligón, 925 F.Supp.2d at 541-45. 37 . See Liability Opinion at Part III.B; Ligón, 925 F.Supp.2d at 541-44. 38 . There could be a simple way to ensure that officers do not unintentionally violate the Fourth Amendment rights of pedestrians by approaching them without reasonable suspicion and then inadvertently treating them in such a way that a reasonable person would not feel free to leave. Officers could, for example, begin De Bour Level 1 and 2 encounters by informing the person that he or she is free to leave. There is no constitutional requirement for officers to inform people that they are free to leave. Cf. Ohio v. Robinette, 519 U.S. 33, 35, 117 S.Ct. 417, 136 L.Ed.2d 347 (1996) (<HOLDING>); Schneckloth v. Bustamonte, 412 U.S. 218, 227,
holding that the fourth amendment does not require that a lawfully seized defendant must be advised that he is free to go before his consent to search will be recognized as voluntary holding that a detained defendants consent to search his car was voluntary even though the police did not tell him he was free to leave holding that police must prior to entering the home inform the person from whom consent is sought that he or she may lawfully refuse to consent to the search holding inter alia that a search can be consented to even if a defendant to be advised that he is free to go holding that implied consent that has been withdrawn or revoked by a suspect cannot serve as a substitute for the free and voluntary consent that the fourth amendment requires