California, United States of America
The following excerpt is from People v. Marquez, A155723 (Cal. App. 2019):
their patrol car alongside defendant at night, then exited their car and asked incriminating questions of defendant but did not use or threaten physical force and did not command defendant to do anything]; People v. Terrell (1999) 69 Cal.App.4th 1246, 1251, 1254 [consensual encounter found where two officers approached defendant and engaged in brief conversation].)
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