California, United States of America
The following excerpt is from People v. G.O. (In re G.O.), G055207 (Cal. App. 2018):
Other cases discuss circumstances more akin to those here. In People v. Perez (1989) 211 Cal.App.3d 1492 (Perez), a police officer parked his patrol car in front of the defendant's vehicle, leaving "plenty of room" for the defendant to drive away, and activated both spotlights on the patrol car "to get a better look at the occupants and gauge their reactions." (Id. at p. 1494.) The officer then walked over to the car, tapped on the window, and asked the driver to roll down the window. (Ibid.) The Perez court held no detention had occurred because the officer "left room for defendant's car to leave," "did not activate the vehicle's emergency lights" and "turned on the high beams and spotlights only." (Id. at p. 1496.)
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