Spotlighting Suspect Vehicles

• Spotlighting a Vehicle
• Totality of the Circumstances; Consensual Encounters vs. Detentions
• A “Show of Authority” and Detentions

The police illuminating the inside of a vehicle with a spotlight does not constitute a detention absent other circumstances that would cause a reasonable person to believe he was not free to leave.  Whether or not a police officer illuminating a vehicle’s interior with his or her spotlight constitutes a “show of authority” sufficient to cause a detention of the vehicle’s occupants requires a consideration of the totality of the surrounding circumstances.

At around 8:45 p.m. on a March evening (relevant only to the fact that it was dark out), San Joaquin County Sheriff’s Deputy Joel Grubb, in uniform, was patrolling a Stockton residential neighborhood in a marked patrol car with his headlights’ high beams on for “extra visibility.” The area was known for narcotics sales and weapons possession.  Deputy Grubb drove past a BMW legally ....