How have courts interpreted consent to search searches in the context of a traffic stop?

^2. On cross-examination, Groves said appellant's face was not "lit up enough so that [he] could see details" at the time appellant consented to a search.

^3. Miranda v. Arizona (1966) 384 U.S. 436.

^4. People v. Jones (1991) 228 Cal.App.3d 519 [A police officer was on patrol in an area of Oakland know for high narcotics activity, sales, and use. The officer saw a group of men on a street corner and watched one man hand money to the defendant. The officer pulled his patrol car to the wrong side of the road and parked diagonally against the traffic about 10 feet behind defendant and the other men in the group. As the officer stepped out of his car, defendant began to walk away. The officer asked defendant to stop and defendant complied and immediately reached toward his left-rear pocket with his left hand. The officer reached out, grabbed defendant's forearm, and pulled defendant's fingers from the pocket. As the officer did so, he saw a bag of narcotics in the pocket. The appellate court affirmed, holding defendant was detained because a reasonable man would not believe he was free to leave when directed to stop by a police officer who arrived suddenly and parked his car to obstruct traffic.]

People v. Roth (1990) 219 Cal.App.3d 211 [During the early morning hours of February 7, 1988, two San Diego County sheriff's deputies conducted a security check of closed businesses in an Alpha Beta shopping center. They saw defendant, dressed in bulky clothing, walking in the parking lot about 30 yards from the Alpha Beta store. One deputy shined a spotlight on defendant and stopped the patrol car. Both deputies got out of the car and one approached defendant saying he wanted to speak with defendant. Defendant came to the patrol car and one deputy asked what he was doing in the area. Defendant claimed he was going to the store but the deputy said it was closed. Defendant next claimed that he was going to look for junk in the store dumpsters. In response to a deputy's question, defendant acknowledged that he was carrying weapons. The deputy had defendant spread-eagle on the patrol car and removed a hammer, unloaded .22 automatic pistol, and three knives from his person. The appellate court held that the officers acted illegally in detaining defendant and patting him down.]

People v. McKelvy (1972) 23 Cal.App.3d 1027 [During the 3:00 a.m. hour of April 11, 1970, San Bernardino police saw defendant walking across the front lawns of residences. The officers considered the behavior peculiar because there were sidewalks in the area. In addition, a curfew forbade loitering between 11:45 p.m. and 6:00 a.m. The officers put a spotlight on the defendant and, as they did so, defendant placed a small, dark-colored object in his front pocket. The officers stopped their patrol vehicle, got out, and carried firearms. One officer approached defendant with a shotgun. The appellate court held that denial of suppression could not be upheld on the basis of voluntary consent to seizure, search incident to arrest for curfew violation, or search incident to a detention for investigation.]