People v. Castaneda

In People v. Castaneda (1995) 35 Cal.App.4th 1222, a police officer approached Castaneda as he was sitting in the passenger seat of an illegally parked car. (Castaneda, supra, 35 Cal.App.4th at p. 1225.) The officer requested identification and asked Castaneda who owned the car. (Id. at pp. 1225-1226.) Castaneda handed the officer his identification card and told him the car was owned by a friend who lived in a nearby apartment but he did not know which apartment his friend resided in. (Id. at p. 1226.) The officer radioed for information on the car's registration as well as Castaneda's warrant status while another officer filled out a parking citation for the car. (Ibid.) He received information that there was an outstanding warrant for Castaneda's arrest. (Ibid.) A search incident to Castaneda's arrest on the warrant turned up drug contraband on his person. (Ibid.) On appeal, Castaneda contended that no justification existed to support his detention. (Ibid.) The Court of Appeal reasoned that Castaneda was not detained when the officer approached him and began asking him questions, nor when the officer asked him to produce identification. (Id. at p. 1227.) However, the court held that Castaneda was detained once he "complied with [the] request and submitted his identification card to the officers," because at that point, a reasonable person would not have felt free to leave. (Id. at p. 1227.) Nevertheless, the court upheld the denial of Castaneda's suppression motion on the grounds that a brief detention--long enough to verify ownership of the vehicle--was in fact justified because the car was illegally parked and the officer could reasonably suspect that Castaneda was not being honest about its ownership. (Id. at pp. 1227-1228.) In short, the defendant was sitting in an illegally parked vehicle when the police approached him and asked for his identification and ran a warrants check while writing a ticket for the illegally parked vehicle. (Id. at pp. 1225-1226.) The court found that "although Castaneda was not restrained by the officer asking for identification, once Castaneda complied with his request and submitted his identification card to the officers, a reasonable person would not have felt free to leave. And once the officers began writing the parking ticket, no one would have tried to walk away from them." (Id. at p. 1227.)