California, United States of America
The following excerpt is from People v. Murray, F040933. (Cal. App. 2003):
For example, in People v. Franklin (1987) 192 Cal. App. 3d 935, 237 Cal. Rptr. 840, we found that an officer's spotlighting a pedestrian and pulling his patrol car to the curb behind the pedestrian was a consensual encounter. While the combination of the spotlight with the officer's parking the patrol car, the pedestrian might rightly "feel himself the object of official scrutiny," we concluded that such directed scrutiny does not amount to a detention.
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