California, United States of America
The following excerpt is from People v. Espinoza, F071891 (Cal. App. 2016):
Finally, in People v. Banks (1990) 217 Cal.App.3d 1358, the officer parked behind an already parked vehicle and approached the driver to question him. The appellate court rejected the argument that this constituted a detention. (Id. at p. 1362.)
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