¶ 1. This is a review of a published decision of the court of appeals,1 affirming the convictions of Charles Young (Young) for possession of marijuana, resisting an officer, and obstructing an officer. Prior to trial, Young moved to suppress evidence *10of marijuana on grounds that it was obtained pursuant to an illegal seizure. The circuit court for Kenosha County, Michael S. Fisher, Judge, denied Young's motion, finding that a Kenosha police officer had reasonable suspicion to initiate an investigatory stop.
¶ 2. Young raises three issues on appeal. First, he argues the marijuana seized incident to his arrest should have been suppressed because the officer lacked reasonable suspicion when he initiated contact. Second, Young asserts that his conviction for obstruction should be reversed because the officer lacked reasonable suspicion at the time he ordered Young to stop, and therefore, the officer was not acting with lawful authority. Third, Young contends that his conviction for resisting should be reversed because the officer lacked reasonable suspicion when he chased and physically apprehended Young, and therefore, the officer was not acting with lawful authority.
¶ 3. Critical to resolving these issues is the question of when a "seizure" occurs under the Fourth Amendment. Young maintains that a person is seized "only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave," which is the test first articulated in United States v. Mendenhall, 446 U.S. 544, 554 (1980). The State takes the position that a person is seized when an officer applies physical force, however slight, to restrain the person's movement or when the person submits to a show of authority. This is the test in California v. Hodari D., 499 U.S. 621, 626 (1991).
¶ 4. In State v. Kelsey C.R., 2001 WI 54, ¶ 33, 243 Wis. 2d 422, 626 N.W.2d 777, this court adopted the Hodari D. test "for when a seizure occurs." Nevertheless, Young argues that Article I, Section 11 of the *11Wisconsin Constitution provides greater protections than the Fourth Amendment and that this court should join the state courts that choose to follow Mendenhall rather than Hodari D.
¶ 5. After considering the relative merits of the Mendenhall and Hodari D. tests, we believe that the two tests can coexist and that the Hodari D. test applies when a suspect refuses to submit to a show of authority. On the facts, we reach the following conclusions: First, the Kenosha police officer had reasonable suspicion for an investigatory stop of the parked car in which Young was sitting. We need not decide whether the car and the occupants other than Young were seized. Second, when the officer ordered Young to return to the car after Young started to run away, the officer had reasonable suspicion to believe Young was committing a crime. Third, applying Hodari D., Young was not seized within the meaning of the Fourth Amendment until the officer physically detained him. Accordingly, the officer lawfully seized Young, and we affirm Young's convictions on all three counts.
I. FACTS AND PROCEDURAL HISTORY
¶ 6. By October 2002 City of Kenosha Police Officer David Alfredson (Alfredson) had been a member of the Kenosha police force for more than seven years. During that entire time he patrolled Area 15, a sector of the city that included 52nd and 53rd Streets and 21st Avenue. Fifty-second Street was the site of two popular bars, The Barn and Coins, and had become "a problem area" for the police. There were problems with fights ("a lot of fights"), drinking in cars, and drug use outside the two establishments. Neighbors had complained to elected officials and law enforcement about people leaving beer bottles in their yards, playing loud music, and *12talking boisterously as they came and went. Littering had become so serious that the two bars sent people out after closing to pick up beer bottles to minimize complaints. Fifty-second Street had become a priority area for police patrol, and it was heavily patrolled after 10:00 p.m.
¶ 7. On the evening of October 26, 2002, Officer Alfredson was driving south on 21st Avenue, a narrow residential street around the comer from The Barn. At approximately 11:40 p.m., he spotted an unfamiliar car with Illinois license plates, parked on the right side of the street along with other cars. There were five people sitting in the car. Alfredson did not stop, but continued driving, turning right on 53rd Street.
¶ 8. Alfredson had developed a regular practice of looking for occupied cars as he patrolled the neighborhood near the bars. When he observed an occupied car, he would continue on his patrol and double back some time later to check whether the car was still occupied. If the car was still occupied, he would stop and investigate. He estimated that he had made dozens of similar stops in the preceding year.
¶ 9. Traveling back to 52nd Street, Alfredson stopped near The Barn to break up a heated argument and disperse the participants. He then went back to his marked squad car, turned the corner, and drove again down 21st Avenue. He saw the same car with Illinois plates, still occupied with five people. His interest piqued, Alfredson decided to stop and investigate. It was 11:49 p.m. At the motion to suppress hearing, Alfredson testified:
[The car] was still occupied with five people in it. That length of time, they would have had time there to park and go out somewhere. They would have more than enough time to go out and do that, so it [aroused] my *13suspicion for possible drinking or narcotics; so I'll stop and check it out.
¶ 10. Because another car was parked directly behind the car in which Young was seated,2 Alfredson stopped his squad in the middle of the street next to the car behind Young's car. He illuminated Young's car with his spotlight, and turned on his flashing emergency lights to alert other vehicles that his squad had stopped. He did not activate his red-and-blue rolling lights, but did notify "Dispatch" of the Illinois license.
¶ 11. Before Alfredson could get out of his squad, Young exited his car from the rear passenger-side door. In response, Alfredson got out of his car. At the suppression hearing, Alfredson described what happened next;
1 ordered him back into the vehicle. He turned and started walking away from the vehicle. I then yelled louder. I said, "Get back in that car right now." And I started heading toward him around my squad. He turned and looked at me and started running up toward the house directly to the west of him. He ran up to the porch and tried to get into the door. I was able to close up on to him. I grabbed him by the back, and I was able to grab one arm; and I told him to knock it off, stop right here, police. He turned around and looked at me and got his arm out of his coat. I re-secured the arm, and I had him by the collar. I said, "Stop resisting." He continued to struggle.
Eventually, Alfredson subdued and handcuffed Young.
¶ 12. In the course of the struggle, Young slipped out of the coat he was wearing and threw it towards the door of the house. Later, Alfredson found a vial containing marijuana inside a pocket of the coat.
*14¶ 13. The Kenosha County District Attorney charged Young with possession of THC as a repeater, in violation of Wis. Stat. §§ 961.41(3g)(e) (2003-04),3 961.48(1), and 939.62(l)(b); obstructing an officer as a repeater, in violation of Wis. Stat. §§ 946.41(1) and 939.62(1)(a), for running from Alfredson after being ordered to stop; and resisting an officer as a repeater, in violation of §§ 946.41(1) and 939.62(l)(a), for struggling with Alfredson when Alfredson tried to arrest him.
¶ 14. Young pleaded not guilty and moved to suppress the marijuana, arguing Alfredson lacked reasonable suspicion for an investigatory stop, and thus, the evidence was obtained pursuant to an illegal stop. The circuit court denied Young's motion, finding that the officer had reasonable suspicion at the time he initiated the investigatory stop.
¶ 15. After a one-day trial, the jury found Young guilty of all three counts. The circuit court sentenced Young to two and one-half years for possession of THC, with initial confinement of one and one-half years and one year of extended supervision. It withheld sentence and imposed two years probation consecutive to Young's prison sentence for the counts of obstructing and resisting.
¶ 16. Young appealed the denial of his motion to suppress. The court of appeals affirmed. State v. Young, 2004 WI App 227, 277 Wis. 2d 715, 690 N.W.2d 866. Applying Hodari D., the court of appeals held that Alfredson did not seize Young until he grabbed him on the porch of the house, by which time Alfredson had either reasonable suspicion or probable cause of Young *15committing a crime. See Young, 277 Wis. 2d 715, ¶¶ 18-19. Notably, although the court of appeals affirmed the circuit court, it expressed serious doubt about the wisdom of following Hodari D., stated a preference for the Mendenhall test for seizure, and urged this court to reconsider its adoption of Hodari D. See Young, 277 Wis. 2d 715, ¶¶ 20-26. We ultimately accepted review.
II. STANDARD OF REVIEW
¶ 17. Whether a person has been seized is a question of constitutional fact. State v. Williams, 2002 WI 94, ¶ 17, 255 Wis. 2d 1, 646 N.W.2d 834. As such, we accept the circuit court's findings of evidentiary or historical fact unless they are clearly erroneous, but we determine independently whether or when a seizure occurred. See id. Similarly, in reviewing a motion to suppress, we employ a two-step analysis. State v. Dubose, 2005 WI 126, ¶ 16, 285 Wis. 2d 143, 699 N.W.2d 582. We will uphold the circuit court's findings of fact unless clearly erroneous. Id. Whether those facts constitute reasonable suspicion, however, is a question of law we review de novo. Id.
III. DISCUSSION
¶ 18. The Fourth Amendment of the United States Constitution4 and Article I, Section 11 of the *16Wisconsin Constitution5 protect people from unreasonable searches and seizures. Because not all police-citizen contacts constitute a seizure, however, many such contacts do not fall within the safeguards afforded by the Fourth Amendment. See Terry v. Ohio, 392 U.S. 1, 13 (1968); Williams, 255 Wis. 2d 1, ¶ 20. As long as a reasonable person would have believed he was free to disregard the police presence and go about his business, there is no seizure and the Fourth Amendment does not apply. Florida v. Bostick, 501 U.S. 429, 434 (1991); see Michigan v. Chesternut, 486 U.S. 567, 573 (1988); Williams, 255 Wis. 2d 1, ¶ 4. Generally, therefore, police-citizen contact becomes a seizure within the meaning of the Fourth Amendment "when an officer 'by means of physical force or show of authority, has in some way restrained the liberty of a citizen....'" Williams, 255 Wis. 2d 1, ¶ 20 (quoting Mendenhall, 446 U.S. at 552).
¶ 19. As implied by the Williams decision, this court ordinarily adopts and follows the Fourth Amendment jurisprudence of the United States Supreme Court.
¶ 20. The Supreme Court and this court have recognized two types of seizure. The first type, an investigatory or Terry stop,6 usually involves only temporary questioning and thus constitutes only a minor infringement on personal liberty. An investigatory stop is constitutional if the police have reasonable suspicion *17that a crime has been committed, is being committed, or is about to be committed.7 State v. Waldner, 206 Wis. 2d 51, 56, 556 N.W.2d 681 (1996). An investigatory-stop, though a seizure, allows police officers to briefly "detain a person for purposes of investigating possible criminal behavior even though there is no probable cause to make an arrest." Id. at 55.
¶ 21. Reasonable suspicion requires that a police officer possess specific and articulable facts that warrant a reasonable belief that criminal activity is afoot. Id. A mere hunch that a person has been, is, or will be involved in criminal activity is insufficient. Terry, 392 U.S. at 27. On the other hand, "police officers are not required to rule out the possibility of innocent behavior before initiating a brief stop." State v. Anderson, 155 Wis. 2d 77, 84, 454 N.W.2d 763 (1990). As we have explained:
[Sjuspicious conduct by its very nature is ambiguous, and the [principal] function of the investigative stop is to quickly resolve that ambiguity. Therefore, if any reasonable inference of wrongful conduct can be objectively discerned, notwithstanding the existence of other innocent inferences that could be drawn, the officers have the right to temporarily detain the individual for the purpose of inquiry.
*18Anderson, 155 Wis. 2d at 84. The detention, however, must be no longer than necessary to clarify the ambiguity. See Florida v. Royer, 460 U.S. 491, 500 (1983); State v. Griffith, 2000 WI 72, ¶ 54, 236 Wis. 2d 48, 613 N.W.2d 72.
¶ 22. The second type of seizure, a full-blown arrest, is a more permanent detention that typically leads to "a trip to the station house and prosecution for crime...." Terry, 392 U.S. at 16. An arrest is not constitutionally justified unless the police have probable cause to suspect that a crime had been committed. Royer, 460 U.S. at 496. Probable cause requires that an arresting officer have sufficient knowledge at the time of the arrest to "lead a reasonable police officer to believe that the defendant probably committed or was committing a crime." State v. Secrist, 224 Wis. 2d 201, 212, 589 N.W.2d 387 (1999). Whereas a mere hunch is insufficient to establish reasonable suspicion, reasonable suspicion is insufficient to establish probable cause. Id. Inevitably, the lines between hunch, reasonable suspicion, and probable cause are fuzzy, with each case requiring an examination of the facts.8 That being said, probable cause does not require proof "beyond a reasonable doubt or even that guilt is more likely than not." See id.
¶ 23. Before we determine whether Officer Al-fredson had either reasonable suspicion or probable *19cause to seize Young, it is necessary to address the question of when Alfredson seized Young. The moment of "seizure" is critical for two reasons: (1) it determines when Fourth Amendment and Article I, Section 11 protections become applicable; and (2) it limits the facts we may consider in evaluating whether Alfredson had reasonable suspicion to stop Young, which in turn affects whether Alfredson had probable cause to arrest Young.
¶ 24. There is no doubt Alfredson seized Young when he physically detained and handcuffed Young after the scuffle on the porch. This action clearly restrained Young's liberty, led to a custodial arrest, and culminated in prosecution. See Terry, 392 U.S. at 16.
¶ 25. The more difficult question is whether any of Alfredson's actions prior to the arrest constituted a seizure. Was Young "seized" in a constitutional sense when Alfredson pulled up behind Young's car, activated his emergency flashers, and put his spotlight on the car? Was Young seized when Alfredson first ordered Young to return to the car? Was Young seized when Alfredson ordered Young a second time, but in a louder voice, to return to the car? Was Young seized when Alfredson began chasing Young? Or, did the seizure not occur until Alfredson made physical contact with Young on the porch?
A. When Was Young Seized?
¶ 26. Under Hodari D. and Kelsey, an uncomplied-with show of authority cannot constitute a seizure. Hodari D., 499 U.S. at 629; Kelsey, 243 Wis. 2d 422, ¶ 33. Thus, if Hodari D. applies, Charles Young was not seized when Alfredson illuminated his car with the spotlight; he was not seized either time Alfredson ordered him to *20return to the car; and he was not seized when Alfredson began to chase him. If any or all of these actions constituted a show of authority, they did not effect a seizure because Young did not comply with any of them. Hodari D. compels the conclusion that Young was not seized until Alfredson physically apprehended him on the porch of the house. Under Hodari D. there seems to be no question that the circuit court correctly denied Young's motion to suppress the marijuana, so long as the State could show reasonable suspicion at some point prior to the seizure.
¶ 27. Young, however, argues that we should reject Hodari D. and interpret Article I, Section 11 of the Wisconsin Constitution to afford greater protections to individual liberty interests than does the Fourth Amendment. In support of his position, Young argues that the defect in Hodari D. is that it threatens an individual's privacy rights and liberty interests by unduly restricting the scope of the Fourth Amendment. More specifically, Young argues Hodari D. (1) isolates from scrutiny the initial stages in police-citizen encounters; (2) shifts the focus of the Fourth Amendment from police conduct to the citizen's response to police conduct; and (3) fails to recognize that pursuit and attempted arrest substantially interfere with personal liberty and should therefore be subject to the Fourth Amendment.
¶ 28. Young maintains that a better test of when a seizure occurs is the "objective" Mendenhall standard; that is, a seizure occurs when, in view of all the circumstances surrounding the incident, a reasonable person would have believed he was not free to leave. See Mendenhall, 446 U.S. at 554. Applying Mendenhall, Young contends he was seized the moment Alfredson pulled up behind his car, turned on the flashers, and *21illuminated Young's car with the spotlight, because at that moment no reasonable person would have felt free to disregard the police presence.
¶ 29. The State insists that Alfredson did not seize Young until he physically apprehended Young. Predictably, the State urges us to reaffirm our commitment to Hodari D. and interpret the Fourth Amendment and Article I, Section 11 of the Wisconsin Constitution coextensively. In response to Young's criticism of Hodari D., the State argues that the better policy is to require submission to a show of authority before Fourth Amendment protections apply. This procedure gives officers advance knowledge of what actions are constitutional, because officers have to assume people will obey and that the exclusionary rule will apply if the police exceed their authority. Encouraging people to comply with police orders also minimizes the risks of police pursuit. In sum, the State argues Article I, Section 11 should be interpreted to follow the Fourth Amendment as interpreted in Hodari D.
¶ 30. Typically, this court interprets Article I, Section 11 of the Wisconsin Constitution in tandem with the Fourth Amendment jurisprudence of the United States Supreme Court. Griffith, 236 Wis. 2d 48, ¶ 24 n.10. Of course, we do not always follow the Supreme Court's lead,9 and the Court does not require us to do so when we supplement the United States *22Constitution's protections with protections under our own constitution. See Michigan v. Long, 463 U.S. 1032, 1041 (1983) ("It is fundamental that state courts be left free and unfettered by us in interpreting their state constitutions.").10 We embrace the Fourth Amendment jurisprudence of the United States Supreme Court when we perceive soundness in Supreme Court analysis and value in uniform rules. We follow that course in this case.
¶ 31. In deciding whether to adopt the Hodari D. or Mendenhall framework for seizure analysis under the Wisconsin Constitution, we believe it is necessary to consider how these cases relate to one another, as well as the public policy reasons for and against following Hodari D.
1. Can Hodari D. and Mendenhall Coexist?
¶ 32. Mendenhall defined a seizure as occurring "only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave." Mendenhall, 446 U.S. at 554. In Mendenhall Drug Enforcement Administration (DEA) agents investigating narcotics trafficking in the Detroit Metropolitan Airport approached Mendenhall after she disembarked from a Los Angeles flight because Mendenhall's actions fit the profile of a drug courier. Id. at 547. The agents identified themselves and asked to see Mendenhall's identification and airline ticket; they discovered that the two bore different names. Id. at 547-48. Upon returning both documents *23to Mendenhall, the agents asked her to accompany them to the DEA office, which she did. Id. at 548. Upon reaching the DEA office, the agents also asked for and received Mendenhall's consent to search her handbag and her person. Id. at 548-49. In the course of the search, the agents found heroin. Id. at 549. Before trial, Mendenhall moved to suppress the heroin, claiming she had been seized when the DEA agents first approached her and that they lacked reasonable suspicion at the inception of the stop.
¶ 33. Justice Stewart concluded — although a majority of the Court did not join him — that the agent's approach and Mendenhall's cooperation did not constitute a seizure, because a person is seized "only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave," and that given the conduct of the DEA agents, a reasonable person would have felt free to walk away. Id. at 554-55; see id. at 560 n.l (Powell, J., concurring).11
¶ 34. Subsequently, a majority of the Court adopted Justice Stewart's Mendenhall test for seizure. See INS v. Delgado, 466 U.S. 210, 215 (1984); Chesternut, 486 U.S. at 573; Bostick, 501 U.S. at 434. These cases make clear that either physical force or a show of authority sufficient to give rise to a belief in a reasonable person that he was not free to leave, is necessary for a seizure. Bostick, 501 U.S. at 434; Chesternut, 486 U.S. at 573; Delgado, 466 U.S. at 215.
*24¶ 35. In Delgado and Bostick, as in Mendenhall, the individuals did not flee in response to an official show of authority. In Delgado the plaintiffs answered questions by INS agents at their workplace. Delgado, 466 U.S. at 220-21. The Court concluded that none of the plaintiffs had been seized because, in view of all the circumstances surrounding the incident, a reasonable person would not have believed that he or she was "not free to continue working or to move about the factory." Id. In Bostick the defendant, a passenger on a bus, challenged the search of his luggage as nonconsensual, claiming that police presence on the bus created a coercive atmosphere that induced consent. Bostick, 501 U.S. at 435. The Court reversed the Florida Supreme Court's holding that suppression of cocaine produced by the search was appropriate, and it remanded the case to state court for a determination of whether a reasonable person would have felt free to "decline the officers' requests or otherwise terminate the encounter." Id. at 436. In both cases, the Court applied the Mendenhall test for seizure because the individuals cooperated.
¶ 36. The Court also applied the Mendenhall test in Chesternut where the defendant ran when he saw a police car and was observed discarding controlled substances as he ran. The Court concluded that the police had not made a sufficient show of authority because, although a police car slowly followed Ches-ternut, the police did not activate a siren or flashers, did not order Chesternut to stop, did not display any weapons, and did not maneuver the police car in any way to limit the defendant's movement. Chesternut, 486 U.S. at 575. Absent a show of authority, there was nothing for Chesternut to submit to, and no possibility of seizure.
*25¶ 37. Mendenhall is the appropriate test for situations where the question is whether a person submitted to a police show of authority because, under all the circumstances surrounding the incident, a reasonable person would not have felt free to leave. If a reasonable person would have felt free to leave but the person at issue nonetheless remained in police presence, perhaps because of a desire to be cooperative, there is no seizure. As this court noted in Williams, "most citizens will respond to a police request," and "the fact that people do so, and do so without being told they are free not to respond, hardly eliminates the consensual nature of the response." Williams, 255 Wis. 2d 1, ¶ 23 (quoting Delgado, 466 U.S. at 216).
¶ 38. Hodari D., which was foreshadowed by Justice Kennedy's concurrence in Chesternut, supplements the Mendenhall test to address situations where a person flees in response to a police show of authority. See Hodari D., 499 U.S. at 628. In Hodari D. police officers in an unmarked squad car rounded a corner in a high-crime neighborhood and came upon a group of youths who immediately dispersed at the sight of the car. Hodari D., 499 U.S. at 622-23. One of the officers chased Hodari on foot. Id. at 623. Shortly before the officer caught the suspect, Hodari threw away a rock of crack cocaine. Id. Hodari argued he was seized once he saw the officer pursuing him and that the evidence of the cocaine should be suppressed as the fruit of an illegal seizure. Id. The Court disagreed, concluding that although the officer's pursuit constituted a show of authority and although the officer lacked reasonable suspicion when he initiated the pursuit, Hodari was not seized until the officer tackled him, because Hodari did not submit to the show of authority. Id. at 629. Hence, *26Hodari abandoned the cocaine before he was seized, and it was admissible. Id.
¶ 39. Because Mendenhall and its progeny did not confront the situation where a person refuses to yield to a show of authority, the Hodari D. court found the Mendenhall test insufficient:
[The Mendenhall test] says that a person has been seized "only if," not that he has been seized "whenever"; it states a necessary, but not a sufficient, condition for seizure — or, more precisely, for seizure effected through a "show of authority." Mendenhall establishes that the test for existence of a "show of authority" is an objective one: not whether the citizen perceived that he was being ordered to restrict his movement, but whether the officer's words and actions would have conveyed that to a reasonable person. Application of this objective test was the basis for our decision in ... Chester-nut... where we concluded that the police cruiser's slow following of the defendant did not convey the message that he was not free to disregard the police and go about his business. We did not address in Chesternut, however, the question whether, if the Mendenhall test was met — if the message that the defendant was not free to leave had been conveyed — a Fourth Amendment seizure would have occurred.
Hodari D., 499 U.S. at 628. The Mendenhall test applies when the subject of police attention is either subdued by force or submits to a show of authority. Where, however, a person flees in response to a show of authority, Hodari D. governs when the seizure occurs. Deciding when a seizure occurs is important because the moment of a seizure limits what facts a court may consider in determining the existence of reasonable suspicion for that seizure.
*27¶ 40. The Hodari D. test does not supersede the Mendenhall test, it supplements the Mendenhall test. United States v. Drayton confirms this.12 Drayton, 536 U.S. 194, 201-02 (2002). Decided more than ten years after Hodari D., Drayton retains a Mendenhall-inspired test for seizure, adapted to a police-citizen encounter on a bus. Under Drayton, a person is seized if a reasonable person would not "feel free to decline the officers' requests or otherwise terminate the encounter." Id. at 202 (quoting Bostick, 501 U.S. at 436). Unlike Hodari D., the defendant in Drayton did not flee or attempt to flee from the officers. In a similar vein, this court cited both Mendenhall and Hodari D. in Williams. Thus, the Mendenhall and Hodari D. tests are compatible and can coexist. The applicable test depends upon the facts.13
2. Policy Considerations Encircling Hodari D.
¶ 41. Justice Scalia, the author of Hodari D., gives two policy reasons in support of the Hodari D. test for seizure. Hodari D., 499 U.S. at 627. First, by postponing the moment at which the protection of the exclusionary rule becomes available to an individual who flees from the police until there has been a seizure, Hodari D. encourages compliance with police orders, thereby obviating the need for police pursuits that pose risks to the public. Id. Instead of employing self-help remedies *28like flight, citizens should seek relief from unlawful police interference in the courts through use of the exclusionary rule and, if need be, civil rights suits.
¶ 42. Second, although Hodari D. restricts the reach of the Fourth Amendment, Justice Scalia contends that it will have no adverse effect upon the privacy rights and liberty interests of the citizenry. See id. One purpose of the Fourth Amendment and its exclusionary rule is to deter illegal government activity. State v. Knapp, 2005 WI 127, ¶ 22, 285 Wis. 2d 86, 700 N.W.2d 899 (Knapp II). "Unlawful orders will not be deterred... by sanctioning through the exclusionary rule those [unlawful orders] that are not obeyed." Hodari D., 499 U.S. at 627. Police officers shout "Stop!" or "Get back in that car right now," expecting to be obeyed; the deterrent effect of the exclusionary rule is still realized if it applies only to "successful seizures" resulting from these orders. Id. In short, because the majority of people confronted with a direct command will obey the command, police officers must understand that the exclusionary rule will constrain their conduct in these situations.
¶ 43. Perhaps the most powerful criticism of Ho-dari D. can be found in Justice Stevens' dissent. Much of the scholarly criticism of Hodari D. simply amplifies the points he makes.14 First, Justice Stevens chastises the majority for adopting too literal a construction of the term "seizure" because it limits the application and protective function of the Fourth Amendment to the *29common law conception of arrest, which required physical contact. Hodari D., 499 U.S. at 631-33 (Stevens, J., dissenting). Instead, Justice Stevens argues that because an attempted arrest also infringes upon an individual's privacy and liberty, the Fourth Amendment should apply to unlawful attempted arrests. Id. at 631-32, 637.
¶ 44. Second, Justice Stevens criticizes the majority decision as inconsistent with the Court's precedent in Katz v. United States, 389 U.S. 347 (1967) (holding that the Fourth Amendment protects against "seizures" of oral statements obtained by electronic surveillance), and Terry (holding that the Fourth Amendment extends to investigatory stops that fall short of a common-law arrest), both of which allegedly interpreted the Fourth Amendment expansively to afford greater protection to liberty interests and privacy rights. Hodari D., 499 U.S. at 633-37 (Stevens, J., dissenting).
¶ 45. Third, Justice Stevens criticizes the majority for shifting the analysis of whether a seizure occurs from an objective analysis of how a reasonable person would interpret the police officer's conduct to the individual's reaction to that conduct. Id. at 641, 643. Thus, police officers can create reasonable suspicion or even probable cause where there was none by coercively infringing upon the individual's right to be let alone, and waiting for an arguably suspicious reaction.15 Id. at 645^46 & n.18.
*30¶ 46. Adding to these arguments about individual liberty, Justice Stevens maintains that the majority's decision abandons a standard that permits police officers to "determine in advance whether the conduct contemplated will implicate the Fourth Amendment." Id. at 643-44. Because of these shortcomings, Justice Stevens would reject the Hodari D. test, and instead require a court to evaluate the constitutionality of police conduct based on the conditions at the time the officer took action, when liberty is first restrained and privacy first infringed. Id. at 645.
¶ 47. Although we recognize the strength of these critiques, we remain unconvinced that Hodari D. should be discarded. We acknowledge the potential that police officers may rely upon Hodari D. to manufacture reasonable suspicion by attempting to seize individuals in expectation that they will flee. This is not such a case. There is no indication in the record that Officer Alfredson was attempting to induce flight or other suspicious conduct. On the facts here, the concerns prompting the criticism of Hodari D. appear unwarranted.
¶ 48. We disagree that adhering to Hodari D. will leave police officers unable to determine in advance whether contemplated conduct will implicate the Fourth Amendment. Contra Hodari D., 499 U.S. 643-44 (Stevens, J., dissenting). As Hodari D. and other decisions suggest, most people will acquiesce with a police show of authority, in which case the Fourth Amendment applies and the exclusionary rule will exclude any evidence obtained in the absence of reasonable suspicion. See id. at 627; Drayton, 536 U.S. at 205. Consequently, before initiating an investigatory stop, police officers must presume that the target of the stop will *31comply and the protections of the Fourth Amendment's exclusionary rule will have full effect.
¶ 49. The exclusionary rule is the primary means by which Fourth Amendment rights are protected. Its primary purpose is to deter future unlawful police conduct. See Mapp v. Ohio, 367 U.S. 643, 656 (1961); Knapp II, 285 Wis. 2d 86, ¶ 22. The exclusionary rule is not absolute. Id., ¶ 23. The benefits of any increased deterrence must be weighed against the substantial social costs exacted. Id., ¶ 22. The exclusionary rule "applies only in contexts 'where its remedial objectives are thought most efficaciously served.'" Id., ¶ 23 (quoting Pa. Bd. of Prob. & Parole v. Scott, 524 U.S. 357, 363 (1998)). Because a police officer cannot know in advance that a suspect will flee or not comply with a show of authority, and because a police officer must presume that people will comply with orders and thus the officer must adhere to the Fourth Amendment to prevent the exclusion of evidence, we fail to see how rejecting Hodari D. will further deter Fourth Amendment violations. The benefits of extending the exclusionary rule to situations before seizure, when a person does not comply with a police order, appear to be negligible.
¶ 50. Under Hodari D. the protection afforded by the exclusionary rule remains unless the person confronted by a show of authority chooses to abandon its protective embrace by opting for self-help flight. Under Hodari D. courts have created an incentive for people to obey police orders without creating an incentive for police to violate the Fourth Amendment. Under Hodari D. courts remain the final arbiter of whether police conduct violates the Fourth Amendment, not the citizen on the street.
*32¶ 51. There is one additional policy consideration for following the Hodari D. test: stare decisis. Less than five years ago this court elected to follow Hodari D. Kelsey C.R., 243 Wis. 2d 422, ¶¶ 30-33. Absent special justification,16 such as a showing that our earlier adoption of Hodari D. has resulted in the widespread erosion of liberty interests, we decline to overrule Kelsey C.R.
¶ 52. Given that Young fled in response to a show of authority, Hodari D. supplies the proper analysis to evaluate when Young was seized. Applying Hodari D., we conclude Young was not seized until Alfredson physically apprehended him on the porch because Young did not submit to any show of authority prior to that moment.
B. Was There Reasonable Suspicion or Probable Cause to Justify the Seizure?
¶ 53. Our analysis cannot end here because this case is unlike Hodari D. in one significant respect: Young did not abandon the contraband before he was seized. Thus, we cannot rely on abandonment as the basis for admitting the incriminating evidence. Instead, we must inquire whether Alfredson's search of Young's coat was justified.
*33¶ 54. We begin with the rule that warrantless searches are per se unreasonable under the. Fourth Amendment and Article I, Section 11 of the Wisconsin Constitution. Williams, 255 Wis. 2d 1, ¶ 18. There are, however, " 'specifically established and well-delineated' exceptions to the Fourth Amendment's warrant requirement." Id. (quoting Zafe, 389 U.S. at 357). One of these exceptions is for searches incidental to a lawful arrest. Chimel v. California, 395 U.S. 752, 753 (1969); see also Wis. Stat. §§ 968.10 (authorizing a search incident to arrest) and 968.11 (authorizing a search incident to arrest for the purpose of, inter alia, "[discovering and seizing the fruits of the crime")..
¶ 55. There is a similar, albeit more limited, exception for searches incident to an investigatory stop. See Terry, 392 U.S. at 27; State v. Guy, 172 Wis. 2d 86, 93-94, 492 N.W.2d 311 (1992). If a police officer reasonably suspects a person of committing a crime, he may frisk the person if he reasonably believes the person is armed and if a reasonable officer would have believed the person posed a safety risk to the officer or others. Id. at 93-94; see also Wis. Stat. § 968.25.
¶ 56. We need not resolve whether Alfredson's search of Young's coat was a frisk or a search, because we conclude that Alfredson had probable cause to believe Young had violated Wis. Stat. § 946.41(1)— obstructing an officer — by the time he arrested Young on the porch, thereby justifying a full-blown search.
¶ 57. To prove Young guilty of obstruction, the State was required to show: (1) Young obstructed an officer, meaning his conduct prevented or made more difficult Alfredson's performance of his duties; *34(2) Alfredson was acting in an official capacity; (3) Alfredson was acting with lawful authority; and (4) Young knew Alfredson was acting in his official capacity and with lawful authority and that his conduct would obstruct the officer. See Wis JI — Criminal 1766. Young contests the sufficiency of the evidence as to the third element, whether Alfredson had reasonable suspicion when he ordered Young to return to the car. Without reasonable suspicion at the time he ordered Young to return to the car, Alfredson would have lacked lawful authority. See id.
¶ 58. To determine whether Officer Alfredson had reasonable suspicion to initiate an investigatory stop, we examine the facts leading up to the stop to determine whether these historical facts, viewed from the standpoint of an objectively reasonable police officer, amount to reasonable suspicion. See Maryland v. Pringle, 540 U.S. 366, 371 (2003).
¶ 59. An officer need not dispel all innocent inferences before conducting an investigatory stop. Anderson, 155 Wis. 2d at 84. Indeed, the suspicion necessary to justify an investigatory stop is "considerably less than proof of wrongdoing by a preponderance of the evidence." United States v. Sokolow, 490 U.S. 1, 7 (1989). As a leading commentator notes in regard to reasonable suspicion:
Such generalities as "he didn't look right" will not suffice; like Officer McFadden in Terry, the officer must relate what he has observed, and, when appropriate, indicate why his knowledge of the crime problem and the habits of the residents on his beat or of the practices of those planning or engaging in certain forms of *35criminal conduct gives special significance to what he observed.
4 Wayne R. LaFave, Search and Seizure § 9.5(a), at 476 (4th ed. 2004).
¶ 60. Alfredson testified at a preliminary examination, at a suppression hearing, and at the jury trial. His testimony was consistent.
¶ 61. First, Alfredson testified to his knowledge of the neighborhood. It was "a problem area" with several nearby bars. It was known for fights, drinking in cars, littering, and drug use. The police had made the area a priority for patrol, especially after 10:00 p.m., because of these problems. Many cars were in the area on Saturday, October 26, 2002.
¶ 62. Second, Alfredson testified that he was an experienced officer who had patrolled this area for seven years. He was familiar with local automobiles and local practices. Alfredson understood there was a correlation between people remaining in their cars for an extended time and the use of alcohol and narcotics in those cars. Based on his nightly patrols, Alfredson knew this type of activity was common in the neighborhood.
¶ 63. Third, Alfredson testified to the facts that aroused his suspicion. Specifically, five people had lingered in an unfamiliar car with Illinois license plates for five to ten minutes. It was nearly midnight. Alfredson did not see these people get out to go to a bar or a local party, or come back from one. He did not see them drop off one of their number. If any of the occupants were going to spend the night at a dwelling on 21st Avenue, they could have left the car and gone inside. Alternatively, the whole group might be driving back to Illinois after an evening of drinking. Perhaps they were still drinking in the car. Five people sitting in a car for about ten minutes, around the corner from a major bar, *36shortly before midnight: The facts were not necessarily unusual, hut they were not usual, either.
¶ 64. Although there are innocent explanations for why five people would be sitting in a car for five to 10 minutes, Alfredson was not required to rule out all these potential explanations before initiating his investigation. The officer described the particular facts that made him suspicious and linked those facts to his seven years of experience patrolling the neighborhood. At the time Alfredson stopped his squad car, turned on his flashers, and illuminated Young's car, we think there were sufficient facts for Alfredson to initiate an investigatory stop.17
¶ 65. Determining that Officer Alfredson had reasonable suspicion to initiate an investigatory stop is different from determining that he "seized" the vehicle and its occupants. That is a close question with respect to the persons in the car other than Young. When a marked squad car pulls up behind a car, activates emergency flashers, and points a spotlight at the car, it certainly presents indicia of police authority.18 Yet, not every display of police authority rises to a "show of *37authority" that constitutes a seizure. As both Menden-hall and Hodari D. teach, not every police action, initiative, display of authority, or interaction with a citizen would cause a reasonable person to believe that he was not free to leave. A police officer's actions must be assessed in view of all the circumstances surrounding the incident.
¶ 66. Not every contact between the police and a citizen constitutes a seizure. In this case, the officer did not stop a moving vehicle or a vehicle about to move. Compare State v. Harris, 206 Wis. 2d 243, 557 N.W.2d 245 (1996). Young's car was already stopped and had been parked for some time. When Alfredson's squad approached Young's car, he was not able to pull in behind it, out of the lane of traffic. This presented him with two choices. He could park his car at some distance and proceed on foot, or he could stop in the lane of traffic and turn on some warning lights.
¶ 67. Young concedes that Alfredson had authority to approach the suspect car on foot to check it out and make inquiry. We think, however, that it would be unreasonable to expect an officer, traveling alone near midnight, in a problem area, to leave his squad car and approach a suspicious car full of people, without being able to see clearly the situation into which he was walking. We think this would ask too much and would discourage effective law enforcement.19 Cf. Terry, 392 U.S. at 23 (noting "it would be unreasonable to require *38that police officers take unnecessary risks in the performance of their duties").
¶ 68. Instead, Alfredson turned on his emergency flashers and a spotlight, two actions consistent with a concern for the safety of passing motorists and the safety of the officer. We believe the flashing lights are the same lighting the officer would have used if he had stopped to aid a motorist. The officer never turned on his red-and-blue rolling lights.
¶ 69. On these facts, we are reluctant to conclude that the positioning of the officer's car, together with the lighting he employed, necessarily involved such a show of authority that "a reasonable person would have believed that he was not free to leave." Mendenhall, 446 U.S. at 554. We are not required to make that determination in this case.
¶ 70. Even if we were to determine that the officer's show of authority constituted a seizure and that he did not have reasonable suspicion for an investigatory stop, it would not help Young. Young's situation is governed by a different rule because of Hodari D.
¶ 71. At the very moment Alfredson illuminated the spotlight, Young got out of his car. This might have been a coincidence, but a reasonable officer could suspect that it was not. In response, the officer called out to Young. This call was either not heard or it was ignored. If there were any doubt that Alfredson had reasonable suspicion before he illuminated the car, there can be no doubt that Alfredson had reasonable suspicion after *39Young got out of the car and disregarded Alfredson's first order.
¶ 72. One might argue that at the moment Young exited the car, a reasonable officer in Alfredson's position would have had no way of knowing what the person intended. Alfredson's first order for Young to return to the car may be viewed as a reasonable attempt to clarify the ambiguity in Young's conduct. It is also a standard tactic for police officer safety. Once Young disregarded the command and began to flee, Alfredson had reasonable suspicion to stop Young.
¶ 73. Officer Alfredson testified that after he ordered Young to return to the car the first time, Young "turned and started walking away." We acknowledge that people may have the right to disregard the police and walk away without giving rise to reasonable suspicion. See Illinois v. Wardlow, 528 U.S. 119, 125 (2000). Where a police officer, "without reasonable suspicion or probable cause, approaches an individual, the individual has a right to ignore the police and go about his business." Id. (emphasis added). Under these circumstances, "any 'refusal to cooperate, without more, does not furnish the minimal level of objective justification needed for a [stop] or [arrest].'" Id.
¶ 74. Plainly, however, a person who disregards a police officer's order assumes the risk that the officer cannot establish that he had reasonable suspicion for an investigatory stop. The person who believes he is exercising his Fourth Amendment rights by disregarding the officer may be subjecting himself to criminal prosecution if the officer has reasonable suspicion to make a stop.20
*40¶ 75. Young's actions were not consistent with disregarding the police presence and going about his business. Young had remained in the car for at least five to 10 minutes. The instant Alfredson illuminated Young's car with the spotlight, Young altered his course of conduct and got out of the car. It is improbable that the timing of Alfredson's appearance and Young's abrupt departure, with no word to the officer, were mere coincidence. Young's action smacked of evasion and flight, which can properly give rise to reasonable suspicion when viewed in the totality of the circumstances. See Wardlow, 528 U.S. at 125. Thus, we conclude that Young's evasive action, set against the above-described facts, reinforced reasonable suspicion.
¶ 76. Because Alfredson had reasonable suspicion before he issued his second command for Young to return to the car, we conclude Alfredson was acting with lawful authority when he issued this second order. Thus, there is sufficient evidence in the record for a jury to have convicted Young of obstruction.
¶ 77. As a result of this conclusion, it also follows that when Young disregarded Alfredson's second command to return to the car, Alfredson had probable cause to arrest Young for obstruction. Because a search incident to arrest is one of the exceptions to the warrant requirement of the Fourth Amendment, Alfredson lawfully searched Young's jacket, in which he found the vial of marijuana. See Chimel, 395 U.S. at 763. Thus, the circuit court properly denied Young's motion to suppress evidence of the marijuana.
*41¶ 78. Lastly, we conclude there was sufficient evidence to convict Young of resisting an officer, in violation of Wis. Stat. § 946.41(1). For Young to be guilty of resisting, the State had to prove: (1) Young resisted an officer, meaning he used force to oppose Alfredson; (2) Alfredson was acting in an official capacity; (3) Alfredson was acting with lawful authority; and (4) Young knew Alfredson was acting in his official capacity and with lawful authority and that his conduct would resist the officer. See Wis JI — Criminal 1765. As with his conviction for obstructing, Young only contests the third element; that is, whether Alfredson was acting with lawful authority. Because we have concluded that Alfredson had probable cause to arrest Young for obstruction before he physically apprehended Young, there is sufficient evidence in the record for a jury to have convicted Young of resisting.
IV CONCLUSION
¶ 79. Having considered the relative merits of the Hodari D. and Mendenhall tests, we conclude that the two tests can coexist and that the analysis supplied by Hodari D. applies when a suspect refuses to submit to a show of authority. Because Young fled in response to the police officer's show of authority, Hodari D. supplies the framework to analyze when Young was seized.
¶ 80. On the facts, we conclude the following: First, the Kenosha police officer had reasonable suspicion for an investigatory stop of the parked car in which Young was sitting. We need not decide whether the car and the occupants other than Young were seized. Second, when the officer ordered Young to return to the car after Young started to run away, the officer had reasonable suspicion to believe Young was committing a crime. Third, applying Hodari D., Young was not seized within *42the meaning of the Fourth Amendment until the officer physically detained him. Accordingly, the officer lawfully seized Young, and we affirm Young's convictions on all three counts.
By the Court. — The decision of the court of appeals is affirmed.
State v. Young, 2004 WI App 227, 277 Wis. 2d 715, 690 N.W.2d 866.
For ease of reference, this car will be referred to as 'Young's car" even though he was neither the driver nor the owner.
All subsequent references to the Wisconsin Statutes are to the 2003-04 version unless otherwise indicated.
In relevant part, the Fourth Amendment states: "The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated ...." U.S. Const, amend. IV
In relevant part, Article I, Section 11 states: "The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures shall not be violated ...." Wis. Const, art. I, § 11.
See Terry v. Ohio, 392 U.S. 1 (1968).
The legislature codified the standard for an investigatory stop in Wis. Stat. § 968.24, which provides:
After having identified himself or herself as a law enforcement officer, a law enforcement officer may stop a person in a public place for a reasonable period of time when the officer reasonably suspects that such person is committing, is about to commit or has committed a crime, and may demand the name and address of the person and an explanation of the person's conduct. Such detention and temporary .questioning shall be conducted in the vicinity where the person was stopped.
As the United States Supreme Court has acknowledged: "Articulating precisely what 'reasonable suspicion' and 'probable cause' mean is not possible." Ornelas v. United States, 517 U.S. 690, 695 (1996). "They are commonsense, nontechnical conceptions that deal with the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act." Id. (internal punctuation omitted).
See State v. Knapp, 2005 WI 127, ¶ 59, 285 Wis. 2d 86, 700 N.W.2d 899; State v. Dubose, 2005 WI 126, ¶¶ 40-41, 285 Wis. 2d 143, 699 N.W.2d 582 (noting that although the due process clauses of Article I, Section 8 of the Wisconsin Constitution and the Fourteenth Amendment to the United States Constitution are similar, we retain the right to interpret our constitution to provide greater protections).
See also Knapp, 285 Wis. 2d 86, ¶ 57 (listing United States Supreme Court decisions that acknowledge the right of state courts to afford greater protections under state constitutions).
Three members of the Court (Chief Justice Burger and Justices Powell and Blackmun) concluded that the initial questioning constituted a seizure but that the agents had reasonable suspicion to make the stop. United States v. Mendenhall, 446 U.S. 544, 546 (1980).
See also Kaupp v. Texas, 538 U.S. 626, 629-30 (2003).
Justice Bradley's dissent ignores the fact that a court does not reach the Hodari D. test until a defendant refuses to submit to a police show of authority. Curiously, her dissent relies upon Kaupp v. Texas, 538 U.S. 626 (2003), a per curiam opinion, to intimate that perhaps the Supreme Court has abandoned Hodari D. In response, we note that there was no question of flight in Kaupp; the defendant instantaneously submitted to the police show of authority. See Kaupp, 538 U.S. at 628.
See e.g., 4 Wayne R. LaFave, Search and Seizure § 9.4(d) (4th ed. 2004); Tracy Maclin, "Justice Thurgood Marshall: Taking the Fourth Amendment Seriously," 77 Cornell L. Rev. 723, 745-52 (1992); Thomas K. Clancy, "The Future of Fourth Amendment Seizure Analysis after Hodari D. and Bostick," 28 Am. Crim. L. Rev. 799 (1991).
Stated otherwise, Professor LaFave suggests that Hodari D. will encourage unlawful displays of force that" 'turn a hunch into reasonable suspicion by inducing the conduct justifying the suspicion,' that is, the flight of the individual ultimately stopped." 4 Wayne R. LaFave, Search and Seizure § 9.4(d), at 461-62 (4th ed. 2004) (quoting Commonwealth v. Thibeau, 429 N.E.2d 1009 (Mass. 1981)).
We have recognized several criteria for departing from precedent, including: (1) changes or developments in the law that undermine the rationale behind a decision; (2) the need to make a decision correspond to newly ascertained facts; (3) a showing that a decision has become detrimental to coherence and consistency in the law; (4) a showing that a decision is unsound in principle; and (5) a showing that a decision is unworkable in practice. Johnson Controls, Inc. v. Employers Ins. of Wausau, 2003 WI 108, ¶¶ 98-99, 264 Wis. 2d 60, 118, 665 N.W.2d 257.
The court of appeals believed it was doubtful whether Alfredson had reasonable suspicion to detain Young and the occupants of the car based on these facts. Young, 277 Wis. 2d 715, ¶ 10 n.4.
Although a police officer's use of a spotlight in conjunction with emergency flashers may constitute a show of authority, we note that many courts have concluded that the use of a spotlight is not a show of authority sufficient to effect a seizure. See State v. Baker, 107 P.3d 1214, 1216-18 (Idaho 2004) (use of spotlight is no seizure; collecting cases holding the same); State v. Young, 957 P.2d 681, 688-89 (Wash. 1998) (finding that under the totality of the circumstances, illuminating the defendant *37with a spotlight does not a seizure make). We are mindful that emergency flashers are often used in situations that have nothing to do with investigating criminal activity, and spotlights are likely to be used at night.
At oral argument, Young's attorney suggested that if Alfredson had parked his car down the street or around the corner and approached Young's car on foot to direct inquiries to *38the occupants there would have been no Fourth Amendment violation. Such a suggestion strikes us as impractical and an unjustified impediment to effective police work.
We note that the Supreme Court has held that the Fourth Amendment is not offended when a police officer asks a person *40to identify himself if the officer's inquiry is justified at its inception by reasonable suspicion and the inquiry is related to that suspicion. See Hiibel v. Sixth Judicial District Court of Nevada, Humboldt County, 542 U.S. 177, 185-86 (2004).