Does Using Spotlights or High Beams Amount to Restricting a Contact’s Movement?

FROM THE CLASSROOM 
By Ray Hill 
Professor Emeritus, Santa Rosa Junior College 

Illuminating the Contact Scene 

A former student of mine had a 1538 motion where the public defender centered questioning on the use of high beams, spotlight and “take down” lights during a contact. The defense argued that “over illumination” objectively restrained the person’s freedom of movement. The contact occurred in the upper reaches of a Guerneville canyon, which at night is like working on the dark side of the moon. As it ended up, the individual was carrying a hammer in his belt, had warrants, and a search revealed meth and a smoking pipe.  

The judge dismissed the motion to suppress.  

A reminder of the case law in this area: 

The California Supreme Court has approved the use of high beams and a spotlight during a contact. The decision takes precedence over previous DCA decisions that questioned whether spotlighting and its use would objectively restrain a person’s freedom of movement. 

A San Joaquin County sheriff’s deputy pulled behind a legally parked vehicle on a Stockton residential street in an area known for narcotics sales. Three occupants were seated in the car, the windows were partially down and smoke was emanating from the window ....

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