State v. Alvarenga-Lopez, 494 P.3d 763

At ~1:00 a.m., Officer Boardman ran a registration query on a white Toyota Celica and saw its registered owner was on probation; he followed the Celica after it made several turns and parked mid‑block in front of a house with a "for sale" sign.
Boardman pulled alongside the stopped Celica in a marked patrol car (no lights/siren), observed the driver (Alvarenga‑Lopez) reclining to avoid view, circled the block, parked behind the Celica, and approached the driver's side on foot in uniform with a flashlight.
Boardman asked questions about where Alvarenga‑Lopez was coming from; Alvarenga‑Lopez produced an expired El Salvadoran resident card, admitted he had been drinking and was under 21; Boardman took the ID to run queries and another officer arrived.
After queries, Alvarenga‑Lopez verbally consented to a vehicle search and to a pockets search; while searching, he volunteered there was meth in the center console; Boardman found meth and arrested him.
Alvarenga‑Lopez moved to suppress arguing he was seized when the officer began questioning him at the window (no reasonable suspicion); the district court denied the motion (except for one suppressed statement) finding the initial encounter consensual; the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer's approach/questioning of Alvarenga‑Lopez constituted a Fourth Amendment seizure requiring suppression	Encounter was consensual; officer's questions and flashlight use did not show coercive authority	Officer was seized when officer pulled alongside, parked behind, blocked exit, approached in uniform with flashlight and questioned him without reasonable suspicion	Court: Encounter was consensual; no seizure occurred when officer approached and questioned; evidence not suppressed; decision affirmed

State v. Page, 140 Idaho 841, 103 P.3d 454 (Idaho 2004) (approach/questioning in a public place is consensual absent a show of authority)
Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consensual encounter test: whether a reasonable person would feel free to decline and leave)
United States v. Mendenhall, 446 U.S. 544 (U.S. 1980) (lists factors indicating a show of authority/seizure)
State v. Willoughby, 147 Idaho 482, 211 P.3d 91 (Idaho 2009) (Fourth Amendment not triggered unless encounter is nonconsensual)
State v. Baker, 141 Idaho 163, 107 P.3d 1214 (Idaho 2004) (use of flashlight/illumination does not necessarily constitute a seizure)
State v. Gonzales, 165 Idaho 667, 450 P.3d 315 (Idaho 2019) (bifurcated standard of review for suppression rulings)