Defendant was seen driving fast in a parking lot near a bar after 2 am. Officers parked near him and approached on foot. They shined their flashlights on the driver from both sides. The use of flashlights was not a seizure. State v. Wittenberg, 2023 Iowa Sup. LEXIS 85 (Nov. 17, 2023).
Defendant was parked in front of a house at night and the homeowner called to report a suspicious vehicle. An officer drove up along side the car and a door opened and the officer stopped. He shined the patrol car’s spotlight on the driver and then got out to talk to him. This was not a seizure, as several Eighth Circuit cases have held. State v. Cyrus, 2023 Iowa Sup. LEXIS 84 (Nov. 17, 2023).