In what circumstances will a police officer be held without a warrant or warrant for detention?

In the instant case, the officer was merely cruising along the freeway making general observations in the hope of spotting suspicious activity. His testimony revealed that at this point in time he himself did not feel there was probable cause to stop the vehicle in question and he only used his spotlight to get a better look at the occupants. This momentary use of the spotlight and the notable absence of any additional overt action is in obvious contrast to the activities of the police in the three aforementioned cases and is therefore insufficient to be categorized as a detention under the criteria of People v. Bower.