State Of Washington v. Tamara Marie Larson, 74766-5

Late-night encounter in a 7‑Eleven parking lot in a high drug‑crime area: two plainclothes officers in an unmarked SUV observed Danielle Coakley enter a parked car and recognized her as a drug user.
Officers ran the car's plate, learned it was registered to Tamara Larson (who appeared in a recent drug report), and approached the vehicle; Detective Danke illuminated Coakley and saw small plastic bags in her purse.
Coakley consented to a purse search, admitted she was in the car to buy drugs from Larson, and nodded toward Larson as the dealer; officers did not initially tell Larson this information.
Sergeant Hart asked Larson to exit the vehicle and moved a few feet away to question her; Larson initially refused a vehicle search but later—after being told Coakley admitted drugs were in the car and expressing concern about appearing to cooperate—consented and the officers recovered drugs; Larson then admitted intent to sell.
Larson moved to suppress, arguing she was unlawfully seized before she consented; the trial court denied the motion, she was convicted after a bench trial, and she appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Larson was "seized" (so that subsequent consent was involuntary) when asked to exit and questioned, vitiating consent to search the vehicle	Larson: Asked to exit the car and move several feet was a seizure; that seizure invalidated her later consent	State: Officer actions (asking to exit, calm questioning, no force, no show of authority) were consensual—no Mendenhall seizure factors present	Court: No seizure occurred under Washington (article I, §7) or federal analysis; consent was valid and suppression was denied

Florida v. Bostick, 501 U.S. 429 (1991) (consensual encounters analyzed by whether a reasonable person would feel free to decline officers' requests)
United States v. Mendenhall, 446 U.S. 544 (1980) (show‑of‑authority test and examples of conduct indicating a seizure)
State v. Young, 135 Wn.2d 498 (1998) (adopts Mendenhall framework for Washington article I, §7 seizure analysis)
State v. O'Neill, 148 Wn.2d 564 (2003) (officer approaches parked vehicle, questions, and requests do not necessarily constitute a seizure)
State v. Thorn, 129 Wn.2d 347 (1996) (questioning occupant of parked car did not create coercive environment amounting to seizure)
State v. Harrington, 167 Wn.2d 656 (2009) (cumulative officer conduct can mature into a seizure; frisk request transformed consensual contact into detention)