dissenting.
I agree with the Court that the district court did not clearly err by finding that Craig Sanders voluntarily consented to a search of his motel room and of his person. I respectfully dissent, however, because I do not agree that the district court clearly erred by finding that Sanders did not unequivocally withdraw the voluntary consent to the search of his person. I believe that in reaching its conclusion, the Court has misapplied the appropriate standard of review by not deferring to the district court’s eminently reasonable view of the evidence. The Court’s conclusion conflicts with our well-established case law and the weight of Fourth Amendment jurisprudence from other jurisdictions.
I
The proper disposition of a case on appeal depends, in the first instance, on the appropriate appellate standard of review. As with the question of whether a defendant voluntarily consented to a search, Schneckloth v. Bustamonte, 412 U.S. 218, 248-49, 93 S.Ct. 2041, 36 L.Ed.2d 854 (1973), the question of whether a defendant withdrew that consent is a factual determination. In this case, both the Court and I agree that the clearly erroneous standard of review applies to the district court’s factual finding that Sanders did not unequivocally withdraw his consent to the search of his person. Supra at 9; see also United States v. Gray, 369 F.3d 1024, 1026 (8th Cir.2004) (citing United States v. Brown, 345 F.3d 574, 578 (8th Cir.2003)). I disagree, however, with the Court’s application of the clearly-erroneous standard of review.
“A finding is ‘clearly erroneous’ when although there is evidence to support it, the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed.” United States v. Sanders, 341 F.3d 809, 818 (8th Cir.2003) (quoting United States v. United States Gypsum Co., 333 U.S. 364, 395, 68 S.Ct. 525, 92 L.Ed. 746 (1948)). Stated another way, “[t]o be clearly erroneous, a decision must strike us as more than just maybe or probably wrong; it must ... strike us as wrong with the force of a five-week-old, unrefrigerated dead fish.” In re Papio Keno Club, Inc., 262 F.3d 725, 729 (8th Cir.2001) (quoting Parts & Elec. Motors, Inc. v. Sterling Elec., Inc., 866 F.2d 228, 233 (7th Cir.1988)). The district court’s findings of fact, therefore, cannot be clearly erroneous where there are two permissible views of the evidence. Anderson v. City of Bessemer City, 470 U.S. 564, 574, 105 S.Ct. 1504, 84 L.Ed.2d 518 (1985). “If the district court’s account of the evidence is plausible in light of the record viewed in its entirety, the court of appeals may not reverse it even though convinced that had it been sitting as the trier of fact, it would have weighed the evidence differently.” United States v. Tucker, 243 F.3d 499, 506 (8th Cir.2001) (quoting Bessemer City, 470 U.S. at 573-74, 105 S.Ct. 1504).
Therefore, in order to hold that Sanders unequivocally withdrew his consent, the Court must conclude that the district court’s view of the evidence was unreasonable and impermissible. Instead, the Court refuses to acknowledge the reason*779able conclusion of the district court. As a result, despite conceding the applicability of the more deferential clear-error standard of review, the Court effectively engages in a de novo review of the district court’s factual conclusion. In my view, the district court’s conclusion is supported by the evidence in the record and should be granted the deference afforded a fact-finder under the clearly erroneous standard.
II
At the suppression hearing, Investigator Ryan Abodeely testified that each time he asked Sanders to raise his arms, Sanders “tried to block” the search by lowering his arms. Sanders, however, did not testify that he was trying to prevent the search from proceeding but rather testified that he was only reflexively trying to stop his pants from being pulled downward.2 Although Sanders’s subjective intent in reaching toward his waistband is clear (and clearly contrary to the conclusion reached by the Court today), his subjective intent does not figure into my analysis. The district court correctly applied an objective standard for determining whether consent was unequivocally withdrawn. See United States v. Gray, 369 F.3d 1024, 1026 (8th Cir.2004)(requiring unequivocal act or statement to effectively withdraw voluntary consent to a search). In other words, the district court properly determined the facts surrounding the search based on what a reasonable person would have understood by the exchange between Sanders and Abodeely. See Florida v. Jimeno, 500 U.S. 248, 251, 111 S.Ct. 1801, 114 L.Ed.2d 297 (1991). Neither the Court nor I believe that the district court’s conclusion that consent was not unequivocally withdrawn is based on an incorrect application of the law.
The Court has concluded that the only permissible view of the evidence is that when Sanders lowered his arms, he was attempting to prevent the search of his pockets. In fact, the only evidence supporting the Court’s factual conclusion that Sanders’s actions were clearly designed to prevent Abodeely from searching his pockets is Abodeely’s speculation that Sanders “tried to block my hands.” Supra at 3 (emphasis added). Perhaps this would be the only permissible inference if either Abodeely or Sanders had testified that Sanders made some imequivocal gesture, such as grabbing Abodeely’s hands, putting his own hands over his pockets, or simply saying “stop.” Importantly, however, both Abodeely and Sanders testified that, without saying anything, Sanders simply lowered his arms an unspecified distance each time Abodeely reached into Sanders’s pockets and caused his pants to pull downward.3
*780In determining whether Sanders unequivocally withdrew his consent to the search, it is important to focus on both Abodeely’s and Sanders’s descriptions of the events because this is the only evidence available to the reasonable observer. The reasonable observer does not know Sanders’s purpose in lowering his arms nor does she know what Abodeely thinks Sanders’s purpose might be. Rather, the reasonable observer must rely on what she sees and hears.
I submit that the district court’s conclusion that Sanders did not unequivocally withdraw his consent to search his person is quite reasonable. As the reasonable observer entered the motel room, she would have observed Sanders, his six-year-old grandson and a woman surrounded by evidence of recent drug use. The reasonable observer would not only have witnessed Sanders voluntarily consent to a search of his motel and his person but would also have seen him assisting the search of his person by standing and placing his hands in the air without any prompting from Abodeely. The reasonable observer would have noticed that as Abodeely reached into his pockets, Sanders’s waistband was pulled downward. She would have also observed Sanders lower his arms as his waistband was being pulled downward.4 The reasonable observer would have then watched as Abo-deely stopped the search process and asked Sanders to keep his hands in the air before the search was resumed. This exchange would have occurred four or five times, and each time, the reasonable observer would have seen Sanders comply without hesitation or protest. After the final iteration of the exchange, the reasonable observer would have seen Abodeely place Sanders into handcuffs. She would have listened as Abodeely explained that Sanders was not under arrest but that he was being handcuffed only for the investigators’ safety. Even after being handcuffed, Sanders did not say anything that would have alerted the reasonable observer to a desire that the search be stopped. Finally, the reasonable observer would have watched as the search proceeded without incident until Abodeely discovered that Sanders had eight baggies of crack cocaine and $138 in cash in his pockets. Based on these observations, the district court was quite reasonable in reaching its conclusion that Sanders did not unequivocally withdraw consent.
Ill
“Withdrawal of consent need not be effectuated through particular ‘magic words,’ but an intent to withdraw consent must be made [known] by unequivocal act or statement.” Gray, 369 F.3d at 1026. Statements of impatience and protests to leave, such as “the length of the search [is] ‘ridiculous’ ” and “[we’re] ready to go now,” have been held insufficient to unequivocally withdraw consent. Id. at 1026-27; United States v. Ross, 263 F.3d 844, 845-46 (8th Cir.2001) (holding that statements of impatience did not amount to withdrawal of consent). Further, courts have held that ambiguous actions that may be inconsistent with the progress of a search are not unequivocal acts withdrawing consent. See United States v. Wilmore, 57 Fed. *781Appx. 949, 953 (3d Cir.2003) (unpublished) (taking a step or two backward in order to flee after the officer stated his intent to search the suspect’s person was not an unequivocal withdrawal of consent); United States v. Kubbo, 17 Fed.Appx. 543 (9th Cir.2001) (mem.) (removing the carpet out of the back of a vehicle and folding it over in a manner that indicated to the officers that something was hidden did not impliedly withdraw or narrow the scope of the defendant’s consent). Effective withdrawal of consent, therefore, requires an act or statement clearly and unequivocally contrary to the voluntary consent to a search. See Burton v. United States, 657 A.2d 741, 746-47 (D.C.App.1994) (listing cases where courts have and have not found withdrawal of consent).
The most generous interpretation of Sanders’s action is that lowering his arms somehow reflected his reluctance to allow the search to continue. However, “[m]ere reluctance to a continued search, once an explicit and unambiguous statement of consent has been provided, is not necessarily sufficient to imply a withdrawal [of] such consent.” Kubbo, 17 Fed.Appx. at 545. This is particularly true when the act allegedly withdrawing consent is not accompanied by any statement of protest. See Burton, 657 A.2d at 746 n. 11 (discussing situations where actions clearly inconsistent with consent are not accompanied by statements); cf. Metcalf v. Long, 615 F.Supp. 1108, 1117 (D.Del.1985) (finding consent to search was withdrawn by the suspect’s refusal to provide the officers with the keys to his locked residence and his statement, “If you want to go in there, kick the door in”). For example, voluntary consent to search was not withdrawn where a suspect hesitated before silently acceding to the officer’s request to continue the search. Baxter v. State, 77 P.3d 19, 25 (Alaska App.2003). In this case, Sanders knowingly and voluntarily consented to a search of his motel room and of his person. During the search of his person, Sanders did not attempt to move away from Abodeely, Nease v. State, 484 So.2d 67, 69 (Fla.Dist.Ct.App.1986), did not grab Abodeely’s hands in an attempt to stop the search, Jimenez v. State, 643 So.2d 70, 72 (Fla.Dist.Ct.App.1994), and did not reach into his pockets to purposely obstruct the search, Lowery v. State, 894 So.2d 1032, 1034 (Fla.Dist.Ct.App.2005).
A suspect’s actions in relation to a search are particularly ambiguous when accompanied by continued compliance with an officer’s requests. For example, in State v. Mattison, 352 S.C. 577, 575 S.E.2d 852 (2003), a suspect who dropped his arms to his waist during an attempted search of the area around his waistband did not effectively withdraw his consent because he repeatedly complied with the officer’s request to put his hands back on the hood of a car. Id. at 857 (“We find Mattison’s act of lowering his hands falls far short of an unequivocal act or statement of withdrawal, something found in most withdrawal of consent cases.”). As the arresting officer in Mattison testified,
When I got around to the waistband area, [Mattison] kept, in a nervous manner, reaching his hands back down, which led [to] more suspicion that there might be something down there. He kept putting them down. I told him several times, ‘Keep your hands on the hood or on the trunk.’ He complied. He was very cooperative.
Id. at 854. Similarly, the act of placing his hand in his pocket and turning away from the officer during the course of a consensual search of his person was ambiguous in light of a suspect’s immediate compliance with a request to remove his hand from his pocket. Burton, 657 A.2d at 748. Nowhere in the record is there any support for Sanders’s assertion on appeal that he *782“repeatedly pushed [Abodeely’s] hand away.” Instead, the record clearly shows that Sanders lowered his arms some distance approximately five times, that this caused Abodeely to ask him to raise his arms, and that Sanders did so without comment or hesitation. Like the district court, what I find particularly dispositive in this case is Sanders’s repeated cooperation with Abodeely’s requests to raise his arms so that the search could continue.
Of course, once consent is given, it can be limited during the course of the search. See United States v. Ho, 94 F.3d 932, 936 n. 5 (5th Cir.1996). While an articulated objection to the continuing search is not necessary, the failure to object verbally bears on a court’s consideration of whether the act allegedly withdrawing or limiting consent was unequivocal and unambiguous. Cf. United States v. Espinosa, 782 F.2d 888, 892 (10th Cir.1986) (“Failure to object to the continuation of the search under these circumstances may be considered an indication that the search was within the scope of the consent.”); McNair v. Commonwealth, 31 Va.App. 76, 521 S.E.2d 303, 307 (1999) (holding that a suspect’s failure to withdraw consent to search for “criminal activity” in his home included the top floor because he did not withdraw his consent to search when he observed the officer go upstairs). Certainly by the fifth time he lowered his arms, Sanders was aware of the scope of the investigator’s search. Yet during the course of the entire search, Sanders never articulated anything approximating an objection, and nothing in the record suggests his inability to do so.
The Court relies on the Terry-stop case of United States v. Hanlon for the proposition that when “an officer seizes an item of contraband from an individual's person after having concluded that no weapons are present, the evidence will be suppressed.” 401 F.3d 926, 929 (8th Cir.2005) (affirming the district court’s conclusion that the officer had reasonable suspicion to subject the defendant to a pat-down search for weapons following a traffic stop). However, we need only reach our Terry-stop jurisprudence if Sanders unequivocally withdrew his consent or if his consent was effectively withdrawn when Abodeely placed him in restraints. With respect to the former, as discussed above, the district court did not clearly err. With respect to the latter, placing a suspect in custody as a safety precaution during the course of a consensual search does not, by itself, operate to end a suspect’s consent. See State v. Watson, 151 N.H. 537, 864 A.2d 1095, 1099 (2004) (contrasting a valid search where a suspect is restrained after giving consent with an invalid search where a suspect gives consent after being restrained). For example, in Mattison, the officer properly placed the suspect in handcuffs as a safety precaution after the suspect impeded a consensual search by repeatedly lowering his arms and then returning them to the hood of a vehicle upon request. 575 S.E.2d at 854. Similarly, the Ninth Circuit upheld a consensual search where airport drug investigators placed a suspect in handcuffs while they searched his luggage. United States v. Brown, 884 F.2d 1309, 1310-11 (9th Cir.1989).
Sanders’s erratic behavior as Abodeely was about to discover the contraband indicated that safety precautions might be necessary. After placing Sanders in handcuffs, Abodeely explained to Sanders that he was not under arrest but was placed in restraints as a safety precaution. Sanders then complied with Abodeely’s request, thereby allowing the search to continue. See United States v. Hurst, 228 F.3d 751, 758 n. 3 (6th Cir.2000) (resisting handcuffs and attempting to flee from the scene was too ambiguous to imply unequivocal withdrawal of consent). At no point, either *783before or after being placed in handcuffs, did Sanders state that he wanted to withdraw his consent or limit the scope of the search. Indeed, based on the complete record, a reasonable observer could easily infer that Abodeely was momentarily prevented from continuing the search only by his desire to maintain control over the situation and to ensure the safety of all parties.
IV
To overturn the district court, we must be immediately struck and firmly convinced of the district court’s clear error in failing to find that the act of lowering his arms, without anything more, constitutes an unambiguous and unequivocal withdrawal of consent. The district court found that Sanders did not unequivocally withdraw consent. After thoroughly reviewing all the evidence, I do not believe that the district court’s finding is based on an impermissible view of the evidence. Tucker, 243 F.3d at 506 (recognizing that the Court may not reverse the ' district court’s choice from two permissible views of the evidence). I grant that this case might be close for a fact-finder, but close calls are not appropriate for finding clear error. See United States v. Jones, 254 F.3d 692, 695 (8th Cir.2001) (affirming the district court’s finding that the defendant consented to a search by simply lowering his arms even though the Court would have reached a different conclusion if it were the finder of fact). Based on all the evidence adduced at the suppression hearing and the weight of Fourth Amendment case law, I would hold that the district court’s finding that Sanders did not unequivocally withdraw consent is not clearly erroneous.
For these reasons, I would affirm the district court’s denial of Sanders’s motion to suppress evidence. Accordingly, I respectfully dissent.
. Sanders testified on direct examination at the suppression hearing that the only reason he lowered his arms was to pull his pants up. During cross-examination, he elaborated on why he lowered his arms:
GOVERNMENT: And when you put your hands down, the only thing you were trying to do was pull your pants up?
SANDERS: Yeah, 'cause my pants — ’ cause when you go in my pocket, the him come down like this (indicating), and I'm like, Whoa, what's up.
THE COURT: What came down?
SANDERS: The hands like this (indicating). They were in my pocket, hand, and I’m like, Whoa, what’s up? That’s all. It was just a reflex. That’s all.
. From the transcript of the suppression hearing, we know that Sanders reenacted his gesture for the benefit of the court. See supra n. 2. Unfortunately, limited as we are to the written record, we are unable to discern the extent of Sanders’s gesture. This is why we "review the facts supporting the district court's [suppression ruling] for clear error, mindful that ‘[w]hen applying this standard, we give deference to the fact finder, who had an opportunity to observe the demeanor and credibility of the witnesses.’ ” United States v. *780Hammons, 152 F.3d 1025, 1028 (8th Cir.1998) (quoting United States v. Cunningham, 133 F.3d 1070, 1072 (8th Cir.1998)).
. As Sanders himself testified, it would be quite reasonable for our reasonable observer to conclude that Sanders reflexively lowered his arms in response to his pants being pulled downward. The Court's assertion that Abo-deely did not reach into Sanders's pockets until after he was in handcuffs, supra at 11, is belied by the testimony of Sanders, as quoted supra n. 2.