It was reasonable for the officer to block a car because he reasonably suspected that the person he wanted on an arrest warrant was in it and the honking of the car horn might have been a warning to others of the police presence. And, when the car door opened, the smell of marijuana was evident. United States v. Jackson, 2018 U.S. Dist. LEXIS 155416 (W.D. Tenn. Sep. 12, 2018):
The remaining question as to the stop is whether Mr. Jackson’s detention was reasonable, given the standards (listed above) for evaluating detention rooted in the execution of a search or arrest warrant. The Court concludes that it was. Officer Hallum, when he initially blocked the car, was attempting to prevent flight by the individual subject to the arrest warrant because he believed Ms. Harrison could have been in the car. Moreover, because he knew of the address from prior arrests and other criminal activity and believed that the Kia’s honking horn might have been an attempt to alert those in the home of the police presence, briefly detaining those in the car was a reasonable course of action to take to maintain officer safety. While the third standard, facilitating a more orderly completion of the arrest, may not be present here, the two elements which are present render Officer Hallum’s blocking of the car a reasonable seizure in line with what the Fourth Amendment allows.