indicate a seizure, including “ ‘some physical touching of the person of the citizen.’” Id at 781 (quoting United States v. Mendenhall, 446 U.S. 544, 554, 100 S.Ct. 1870, 1877, 64 L.Ed.2d 497 (1980)). In the process of waking Ries up, the officers grabbed his hands, placed him in handcuffs, rolled him over, and patted the outside of his clothing. We are convinced that a reasonable person, under the totality of these circumstances, would not feel free to leave. Accordingly, we conclude that a seizure occurred. Having determined that Ries was seized, we turn to whether the pat search falls within an exception to the warrant requirement. The district court concluded that the search fell within the emergency-aid exception. See State v. Lemieux, 726 N.W.2d 783, 788-90 (Minn. 2007) (<HOLDING>); see also Lopez, 698 N.W.2d at 23 (concluding
holding that officers warrantless entry was justified to assure safety of person who called 911 holding warrantless entry of residence was justified by need to search for intruders or injured occupants holding that it is permissible under the fourth amendment to detain occupants of a residence while executing a search warrant of the residence holding warrantless search of vehicle was improper where car was not stopped on a highway but was parked at a residence with no occupants inside or near the vehicle and capable of being driven away by the turn of an ignition key holding that in every warrantless entry into private residence state has burden to demonstrate that exigencies of situation made entry imperative