People v. Castaneda (1995)

In People v. Castaneda (1995) 35 Cal.App.4th 1222, the defendant was seated in the passenger seat of an illegally parked car when a police officer asked for his identification and the name of the car's owner. Defendant handed the officer his identification and said that the car was owned by a friend whose residence or whereabouts he did not know. ( Id. at pp. 1225-1226.) By radio, the officer requested information on the car's registration and on defendant. The officer arrested defendant after learning that there was an outstanding warrant for his arrest. In pinpointing the exact moment when a seizure occurred, the Castaneda court noted that the defendant "was not detained simply because an officer approached him and began talking to him. And the officer's requesting identification from him did not--by itself--escalate the encounter to a detention. " However, "once the defendant complied with the officer's request and submitted his identification card to the officers, a reasonable person would not have felt free to leave." ( People v. Castaneda, supra, 35 Cal.App.4th at p. 1227.) The court held that the officer possessed the reasonable suspicion necessary to support the detention because "the officer could reasonably suspect the passenger was not being honest about the car's ownership." ( Id. at p. 1228.) The court stated: "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." (35 Cal.App.4th at p. 1227.) However, the court held it was proper for the officer to be suspicious of Castaneda's denial of ownership, and his detention was not unduly prolonged under People v. McGaughran (1979) 25 Cal.3d 577, 584 no violation of defendant's rights if warrant check can be completed within time needed to complete legitimate business of traffic stop. (Castaneda, supra, 35 Cal.App.4th at p. 1228.)