IA: Use of siren and commands about where to stand during stop was a seizure

“Here, the evidence establishes that Officer Aljets exercised his authority to request Williams stop, rendering the encounter a seizure. The officer testified he ‘hit the siren horn’ which made a ‘whoop whoop’ sound in order to get Williams’s attention. The use of the siren is clearly a show of authority. See Harlan, 301 N.W.2d at 720. After Williams turned around and approached the police vehicle, Officer Aljets requested that Williams stand in front of the squad car. Officer Aljets then began questioning Williams. We conclude, based on our case law and the totality of the circumstances, that Williams was seized. See id.; see also State v. Lowe, 812 N.W.2d 554, 570 (Iowa 2012) (noting that a “commanding” tone of voice is evidence of seizure).” State v. Williams, 2015 Iowa App. LEXIS 1121 (Nov. 25, 2015).