PA: Def who encountered police officer in apt building parking lot as police cars entered with lights and sirens would not feel free to leave

“In viewing the totality of the circumstances surrounding the incident, a reasonable person, innocent of any crime, would not believe that he or she was free to leave. The initial encounter between Officer Smith and Appellant commenced when Officer Smith approached Appellant, displayed his police badge, and twice identified himself as a police officer. Almost simultaneously, police vehicles, with lights and sirens activated, entered the apartment complex parking lot in which Appellant and his vehicle were located. … The arrival of the police vehicles, albeit connected to an unrelated undercover drug operation unfolding in the same parking lot as Appellant’s alleged drug transaction, conveyed to Appellant that he was not at liberty to ignore Officer Smith and go about his business at the time Officer Smith approached Appellant’s vehicle, displayed a police badge, and identified himself as a police officer. …” Commonwealth v. Brame, 2020 Pa. Super. LEXIS 790 (Sept. 15, 2020).