State v. Aronson

A police officer's act of parking several car lengths behind a person's vehicle does not constitute a show of authority or restraint of the person's liberty such that a reasonable person would not feel free to leave.

A police deputy observed defendant driving suspiciously. After defendant parked, the deputy positioned his patrol car behind defendant's at an angle, leaving several car lengths between the two vehicles, and shined the patrol car's spotlight on defendant's car. The deputy arrested defendant for driving under the influence of intoxicants (DUII). Defendant appealed his conviction, arguing that he was unlawfully stopped when the deputy parked behind him and shined the spotlight on defendant's car. Defendant claimed he could not safely have left because he could not see where the patrol car was parked; a reasonable person would not have felt free to leave under the circumstances. Given a lack of evidence that the spotlight effectively blocked defendant's exit, the Court of Appeals agreed with the state that defendant was not stopped under the circumstances. Affirmed.