In Popple v. State, 626 So. 2d 185 (Fla. 1993), the Court defined three levels of police-citizen encounters. The first is the "consensual encounter," which involves minimal police contact and does not invoke constitutional safeguards. See id. at 186. During a consensual encounter, an individual may voluntarily comply with or ignore the request of a police officer. See id. The second is the "investigatory stop," under which an officer may detain a citizen temporarily if the officer has a reasonable articulable suspicion that the person has committed, is committing, or is about to commit a crime. See id. The third level is an arrest, which must be supported by probable cause that a crime has been or is being committed. See id. The Court held that a legally parked car, even one in a desolate area, does not create reasonable suspicion to justify a detention. In Popple, the police only observed the defendant sitting in a legally parked car making furtive movements at 12:55 p.m. prior to the detention. The supreme court found that Popple's suppression motion should have been granted. Under that holding, Taylor's suppression motion was properly granted. The Court set out the levels of police-citizen interactions and the degree of suspicion of criminal activity needed at each level. Significantly, Popple placed the issue of when an individual is detained squarely before us via conflict of decisions on the issue in the district courts, rather than as one of numerous issues raised in a capital case as in Lightbourne. Connecting United States Supreme Court precedent and Florida's "stop and frisk" law, the Court stated: There are essentially three levels of police-citizen encounters. The first level is considered a consensual encounter and involves only minimal police contact. During a consensual encounter a citizen may either voluntarily comply with a police officer's requests or choose to ignore them. Because the citizen is free to leave during a consensual encounter, constitutional safeguards are not invoked. United States v. Mendenhall, 446 U.S. 544, 100 S. Ct. 1870, 64 L. Ed. 2d 497 (1980). The second level of police-citizen encounters involves an investigatory stop as enunciated in Terry v. Ohio, 392 U.S. 1, 88 S. Ct. 1868, 20 L. Ed. 2d 889 (1968). At this level, a police officer may reasonably detain a citizen temporarily if the officer has a reasonable suspicion that a person has committed, is committing, or is about to commit a crime. 901.151, Fla. Stat. (1991). In order not to violate a citizen's Fourth Amendment rights, an investigatory stop requires a well-founded, articulable suspicion of criminal activity. Mere suspicion is not enough to support a stop. Carter v. State, 454 So. 2d 739 (Fla. 2d DCA 1984). While not involved in the instant case, the third level of police-citizen encounters involves an arrest which must be supported by probable cause that a crime has been or is being committed. Henry v. United States, 361 U.S. 98, 80 S. Ct. 168, 4 L. Ed. 2d 134 (1959); 901.15 Fla.Stat. (1991). (Popple, 626 So. 2d at 186.) The Court articulated the standard for distinguishing detentions from mere police-citizen encounters: "Although there is no litmus-paper test for distinguishing a consensual encounter from a seizure, a significant identifying characteristic of a consensual encounter is that the officer cannot hinder or restrict the person's freedom to leave or freedom to refuse to answer inquiries, and the person may not be detained without a well-founded and articulable suspicion of criminal activity. This Court has consistently held that a person is seized if, under the circumstances, a reasonable person would conclude that he or she is not free to end the encounter and depart." Id. at 187-88. The Court stated that whether characterized as a request or an order, an officer's direction to an individual can constitute a show of authority that a reasonable person would not feel free to refuse. See id. at 187. The Court further held that an officer's observation of the defendant sitting in a legally parked car making furtive movements at 12:55 p.m. did not create reasonable suspicion to justify a detention that was initiated by the officer telling Popple to exit his vehicle. See id. at 186-88. In sum, in Popple v. State, the Court explained that there are three levels of police-citizen encounters. The first level is categorized as a "consensual encounter," during which the citizen is free to leave, there is minimal police contact, and Fourth Amendment protections are not triggered. Popple, 626 So. 2d at 186. Under the second and third levels, however, constitutional safeguards are invoked. The second level involves an "investigative stop," during which a police officer may temporarily detain a person only if the officer has a reasonable suspicion that a person has committed, is committing, or is about to commit a crime. Id. The third level concerns an "arrest" and must be supported by probable cause to believe a crime has been or is being committed. Id.