Barrows v. State

In Barrows v. State, 814 P.2d 1376 (Alaska App. 1991), the Court confronted a similar encounter between a police officer and a citizen, and we held that no seizure had occurred. In Barrows, a police officer approached a parked vehicle on foot, questioned the driver briefly, and requested identification. Id. at 1377. The Court concluded that "a reasonable person in this situation would have felt free to refuse to comply with this request", and we therefore held that the officer's actions did not amount to a seizure for Fourth Amendment purposes. Id. at 1379.