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Smith v. State (4th District Court of Appeals, April 25th, 2012).

Reasonable person in defendant's position would not have felt free to leave when a deputy parked “catty corner” to defendant's vehicle, activated his emergency lights, and used his spotlight to illuminate the interior of defendant's vehicle, and thus defendant was seized at that point for purposes of the Fourth Amendment; defendant was legally parked on the side of a residential street, nothing objectively indicated that defendant was in need of aid, and defendant did not exhibit any conduct to indicate that he sought police assistance.

Thus, the marijuana and cocaine found by this officer was the product of an illegal encounter and the State cannot use the evidence against the Defendant.