Gay v. State (2nd District Court of Appeals, May 15th, 2014)

Officer determined not to cite driver during traffic stop for a rolling stop at a stop sign.  But he then asked the driver for consent to search the vehicle.  The driver agreed which rendered the encounter what is deemed a "consensual encounter."  The officer's actions in searching passenger's purse and pill box contained in purse, removing the pill box from the vehicle, and taking box to his patrol car for further investigation resulted in the encounter becoming an investigatory detention, which was not justified by reasonable suspicion of criminal activity.  The Court said the officer's actions would have led a reasonable person to conclude she was not free to leave, and nothing about the pills or pill box gave officer reasonable suspicion that passenger or driver had committed, was committing, or was about to commit a crime.  The evidence was suppressed as the product of an illegal search.