In People v. Laviscount, 116 A.D.3d 976, 978-979, 984 N.Y.S.2d 394, 2014 N.Y. Slip Op. 02798 (2nd Dept. 2014), the Court reversed the trial court's denial of the defendant's motion to suppress the evidence, reasoning that simply because the defendant's vehicle was parked early morning in an area where cars are not usually parked and that the defendant may have moved an object from his dashboard and threw it on the floor of his car was an insufficient basis to justify approaching his vehicle and requesting information.