The Michigan Supreme Court "has categorized police-citizen encounters as falling under three different tiers," and only the third tier—a "full arrest"—requires probable cause. People v. Lefree, No. 317502, 2014 WL 6468187, at *3 (Mich. Ct. App. Nov. 18, 2014) (citing People v. Shabaz, 424 Mich. 42, 56-58 (1985)). "The first tier consists of a police officer asking mere non-coercive questions of a person in a public setting.