People v. Tacardon

Summary

The court held that a police spotlight does not automatically transform an encounter with occupants of a parked car into a Fourth Amendment detention; the determination depends on the totality of the circumstances. On the record presented, the deputy's initial conduct did not detain Tacardon, but the trial court failed to determine whether Tacardon perceived the deputy's detention of the passenger and was thereby detained himself. The judgment was reversed and the matter remanded for that factual determination. No separate opinions are included in this extraction.