California, United States of America
The following excerpt is from People v. Conley, F069679 (Cal. App. 2016):
In a case with similar facts, People v. Perez (1989) 211 Cal.App.3d 1492, the appellate court concluded the encounter was consensual. In Perez, the officer parked near a car, shined the patrol vehicle's spotlight on the car, walked to the car and tapped on the window with a lit flashlight, and the officer asked the defendant to open the window. (Id. at p. 1494.) The appellate court concluded that the officer did not effect a detention. (Id. at p. 1496.)
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