Piggott v. Commonwealth

In Piggott v. Commonwealth, 34 Va. App. 45, 537 S.E.2d 618 (2000), an officer saw the vehicle in which Piggott was a passenger driving the wrong way down a one-way street. 34 Va. App. at 47, 537 S.E.2d at 618-19. After stopping the vehicle, the officer asked Piggott to exit the car and produce identification. 34 Va. App. at 47-48, 537 S.E.2d at 619. The Court held that Piggott was detained when the officer retained his identification for a warrant check. Id. at 49, 537 S.E.2d at 620. The Court found, "a reasonable person in Piggott's circumstances would not have believed that he could terminate the encounter and walk away." Id. at 49, 537 S.E.2d at 619.