In what circumstances will a defendant be detained by a police officer if the officer's actions are very intimidating to a reasonable person?

Conversely, a detention may occur if the officers' actions would be very intimidating to a reasonable person. (People v. Garry (2007) 156 Cal.App.4th 1100, 1109.) For example, in Garry, the officer shined his patrol car's spotlight at defendant, got out of his police car, and "briskly" walked 35 feet in two and one-half or three seconds directly to the defendant. (Id. at p. 1111.) Instead of engaging in conversation with defendant, the officer immediately asked him whether he was on parole and disregarded his claim that he lived a few feet away. (Ibid.) The court held that the totality of the officer's actions was "very intimidating" so as to set an "unmistakable" tone that the defendant was required to comply with the requests. (Italics added.) (Id. at pp. 1111-1112.)