State v. Aronson, 271 P.3d 121

At about 2:00 a.m., deputy observed Aronson’s car parked alone in a shopping center lot and later moved, exiting slowly and returning to the same space.
The deputy stopped behind Aronson’s vehicle at an angle, leaving space to back out; he activated a spotlight for safety and to observe Aronson as he approached on foot.
The deputy approached Aronson, observed signs of impairment, and arrested him for DUII after determining Aronson would not be free to leave.
Aronson moved to suppress the evidence, arguing the spotlight/parking constituted a stop and a seizure without reasonable suspicion.
The trial court denied the motion to suppress; Aronson was convicted on stipulated facts.
On appeal, the court must determine whether the encounter was a stop under Article I, section 9, of the Oregon Constitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the deputy’s actions constitute a stop under Article I, section 9?	Aronson: spotlight and position restrained liberty, constituting a stop.	Aronson: there was a seizure due to show of authority and inability to leave.	No stop under totality of circumstances.
Does shining a spotlight on a vehicle translate into a seizure or show of authority preventing departure?	Aronson: spotlight could block safe exit, creating restraint.	State: spotlight does not by itself create a stop.	Spotlight alone did not constitute a seizure; no stop.

State v. Calhoun, 101 Or. App. 622 (1990) (spotlight and proximity did not convert encounter into a stop)
State v. Deptuch, 95 Or. App. 54 (1989) (spotlight on rear/front of cars not a seizure)
State v. Hemenway, 232 Or. App. 407 (2009) (parking behind a vehicle relevant to free-to-leave analysis)
State v. Ashbaugh, 349 Or. 297 (2010) (definition of seizure under Article I, section 9)
State v. Rodgers/Kirkeby, 347 Or. 610 (2010) (distinguishing seizure from mere conversation)