Read the following excerpt from a US court opinion:
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was justified at its inception and then (2) whether the action was reasonably related in scope to the circumstances for the stop in the first place. Id. at 24, ¶ 27, 170 P.3d at 273 (citing Terry, 392 U.S. at 19-20, 88 S.Ct. 1868). ¶ 46 The second detention started when Officer Craft grabbed Appellant’s arm and informed him he was being detained. Men-denhall, 446 U.S. at 553, 100 S.Ct. 1870 (A person is “seized” within the meaning of the Fourth Amendment only when by means of physical force or show of authority his freedom of movement is restrained.). Because Officer Craft and Appellant were engaged in a consensual encounter immediately prior to this point, Appellant was not seized and the Fourth Amendment was not implicated. United States v. Munoz, 590 F.3d 916, 920 (8th Cir.2010) ; United States v. Flores, 474 F.3d 1100, 1103
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What is the most suitable continuation to the opinion? Your options are:
A. holding officers request for passengers identification during stop constituted lawful consensual encounter
B. holding that a traffic stop is valid under the fourth amendment if the stop is based on an observed traffic violation or if the police officer has reasonable articulable suspicion that a traffic or equipment violation has occurred or is occurring
C. recognizing that once a completed traffic stop evolves into a consensual encounter there is no seizure and the fourth amendment is not implicated
D. holding that the officers mere use of her spotlight and flashlight did not transform the consensual encounter into an investigatory stop
E. holding that the return of a defendants drivers license after a traffic stop can convert what was a brief seizure into a consensual encounter even where the officer questions the defendant about criminal activity immediately thereafter
Reply with [A, B, C, D, E] only.