(stating that probable cause to arrest exists when officer has “reasonable ground for belief of guilt that was particularized with respect to the person to be ... seized”) (internal quotation marks omitted). Accordingly, the district court properly denied the motion to suppress, and we affirm the court’s judgment. We deny Holland’s motion to file a pro se supplemental brief and dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. AFFIRMED. * The Government argues that, in determining whether a seizure occurred, we should apply the "force or submission” standard set forth in California v. Hodari D., 499 U.S. 621, 626, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991) (<HOLDING>). The Govern ment contends that, because
holding iowa common law touching assault met use of physical force required for enhancement under 18 usc  922g9 be cause any physical contact by necessity requires physical force to complete holding that  2241a1 requires actual use of force meaning use of such physical force as is sufficient to overcome restrain or injure a person holding that an arrest requires either physical force  or where that is absent submission to the assertion of authority holding that an arrest may involve either 1 taking the alleged violator into exlended physical custody or 2 issuing the individual a citation and noting that when we use the word arrest in this opinion we refer to physical arrest holding that emotional distress requires a showing of either physical symptoms or mental illness