by physical force occurs when there is “a governmental termination of movement through means intentionally applied.” Brower v. Cnty. of Inyo, 489 U.S. 593, 597, 109 S.Ct. 1378, 103 L.Ed.2d 628 (1989) (emphasis omitted) (analyzing whether a seizure by physical force occurred when a fleeing subject ran into and was killed on impact with a police-created roadblock set in place to stop the subject); Hodari D., 499 U.S. at 624, 111 S.Ct. 1547 (“From the time of the founding to the present, the word ‘seizure’ has meant a taking possession. For most purposes at common law, the word connoted not merely grasping, or applying physical force to, the animate or inanimate object in question, but actually bringing it within physical control.”) (internal citations omitted); id. at 629, 111 S.Ct. 1547 (<HOLDING>); see also Cnty. of Sacramento v. Lewis, 523
holding no seizure occurred until hodari was physically apprehended ie tackled to the ground to stop his flight holding that where the police roadblock was intended to stop brower by physical impact and did so a seizure occurred holding that no seizure occurred where shots were fired at a truck but did not hit the suspect because they failed to produce a stop holding no seizure occurred when after defendant began to walk away officer directed him to stop holding that flight from police can help establish reasonable suspicion for an investigatory stop