State of Arizona v. Carlos Ubaldo Gonzalez, 235 Ariz. 212

Marana police investigated a daytime suspicious-activity call at a restaurant parking lot based on a 9-1-1 report describing three individuals near a parked rental car.
Gonzalez’s car was parked in a space with a fixed barrier that blocked its exit; the officer parked behind and to the rear of the car, creating a physical constraint.
The officer did not use sirens or spotlights but activated rear deck lights and approached on foot without drawing a weapon.
As the officer approached Gonzalez’s vehicle, he smelled marijuana; the central question was whether Gonzalez had been seized before that odor was detected.
The trial court found no seizure before the odor and denied suppression; the appellate court ultimately affirmed the convictions, holding there was no unlawful seizure prior to sensing the odor of marijuana.
The court relied on Canales to analyze when a seizure occurs and concluded blocking the vehicle plus approach constituted a show of authority, but no seizure occurred until the odor was detected or the occupants submitted to authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gonzalez was seized before the odor of marijuana was detected.	Gonzalez argues blocking and the approach conveyed interrogation, constituting a seizure.	State relies on Canales to permit seizure analysis; blocking alone may not be seizure absent submission.	No seizure occurred before odor; suppression properly denied.

State v. Canales, 222 Ariz. 493 (Arizona App. 2009) (show of authority near vehicle supported seizure when deputy blocked and spotlighted vehicle)
G.M. v. State, 19 So. 3d 973 (Fla. 2009) (not free to leave; officer appearance at window later indicated seizure)
United States v. See, 574 F.3d 309 (6th Cir. 2009) (precedent on seizure when officer blocks vehicle during investigatory stop)
United States v. Burton, 441 F.3d 509 (7th Cir. 2006) (illustrative of blocking as showing authority during stop)
Leaf v. Shelnutt, 400 F.3d 1070 (7th Cir. 2005) (seizure analysis when subject aware of police presence)