People v. Brown

Opinion

CORRIGAN, J.

A deputy sheriff investigating an emergency call of a fight in progress pulled his patrol car behind a parked vehicle and activated the emergency lights. Approaching the car, he saw defendant Shauntrel Ray Brown sitting behind the wheel, apparently intoxicated. We conclude Brown was detained when the emergency lights were activated. A reasonable person under the circumstances would not have felt free to leave and Brown submitted to the show of authority by remaining in his parked car. We further conclude that Brown’s brief detention was supported by reasonable suspicion.…