State v. Canales
In State v. Canales, 222 Ariz. 493,7-9, 217 P.3d 836, 838 (App. 2009), a sheriff's deputy was dispatched to an apartment complex at night to investigate a suspicious vehicle. 222 Ariz. 493,2, 217 P.3d at 837.
The deputy parked behind a car matching the description of the vehicle and shined his patrol car's spotlight toward it. Id.
When the officer got out of his car and walked to the suspicious car, he saw the defendant place a beer behind the passenger seat and smelled alcohol. Id.
The Court upheld the trial court's grant of a motion to suppress, finding that Canales had been detained. Id.8. Specifically, the Court concluded that the deputy's actions in making it physically impossible for Canales to leave and shining the spotlight while approaching the driver's door "conveyed to Canales that he was the subject of the inquiry," and that "a reasonable person would not have believed he was free 'to disregard the police and go about his business.'" Id.