State v. Richcreek
In State v. Richcreek, 187 Ariz. 501, 930 P.2d 1304, 1308 (Ariz. 1997), police also responded to a single-car accident. 930 P.2d at 1305. When the police arrived at the scene, the driver of the car was not there. Id.
The police began to search for injured passengers and otherwise investigate the scene. Id. As they did so, the officers noticed a car approach the scene, slow almost to a stop, and pull over to the side of the road before driving away. Id.
One of the officers at the scene thought that the driver of the car could have been the absent driver of the wrecked car or someone who knew the driver. Id. Therefore, the officer stopped the car. Id. Following the stop of the car, the police learned that the car was stolen and arrested the driver. Id. at 1306.
The Arizona Supreme Court held that the evidence obtained pursuant to the stop should be suppressed because "the forced stop of an automobile without the least articulable suspicion of criminal activity is an unconstitutional seizure under the Fourth Amendment." Id. at 1308.