If the metal in a transition metal complex with coordination number of four is low spin, it will be square planar. If the metal is high spin, it will be tetrahedral. To figure out if the metal is high or low spin you have to look at both the identity of the metal and the ligands attached to it. Here are some general rules:
Any 5d transition metals will be low spin.
4d transition metals will prefer low spin unless the ligand is low in the spectrochemical series (i.e. a halogen).
3d transition metals will prefer high spin unless the ligand is high in the spectrochemical series (i.e. a ligand capable of pi backbonding).