California, United States of America
The following excerpt is from People v. Mitchell, B256986 (Cal. App. 2015):
"'[E]ach case must be considered in the context of the totality of its circumstances.' [Citation.] Thus, '[i]n some cases a shorter distance may suffice in the presence of other factors, while in others a longer distance, in the absence of other circumstances, may be found insufficient.' [Citation.]" (People v. Corcoran (2006) 143 Cal.App.4th 272, 279.)
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