NJ: Blocking car and shining light into car then approaching car was an investigative detention

“Defendant was faced with an investigative detention once the officer blocked in her vehicle, directed the patrol car’s alley light to shine into her car, and then approached her driver’s-side window to address her. Under the totality of the circumstances, a reasonable person would feel the constraints on her freedom of movement from having become the focus of law enforcement attention. Accordingly, an investigative detention had begun. Reasonable articulable suspicion did not ripen prior to the officer’s subsequent exchanges with defendant.” State v. Rosario, 2017 N.J. LEXIS 584 (June 6, 2017).