State v. Brown, 427 P.3d 221

Deputy Samerdyke observed defendant's car outside a bar with a known drug dealer nearby, then turned and followed the car for ~10–15 minutes at close range after the car left.
The car drove into a rural area, defendant made evasive turns, and the deputy briefly lost and then located the car behind a closed commercial nursery; he called for backup.
Two marked patrol cars converged from opposite sides behind the building; the officers parked without blocking the car, exited, and approached defendant and a passenger.
Samerdyke questioned defendant about permission to be on the property, an absent passenger, and a drug dealer he had seen earlier; Rice separated defendant and the passenger.
Alone with Samerdyke, defendant—after questioning about drug use—admitted to marijuana and consented to a search; officers then found marijuana paraphernalia and methamphetamine.
Defendant moved to suppress the methamphetamine as the product of an unlawful stop; the trial court denied the motion; on appeal the court considered whether the encounter amounted to a seizure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant was "stopped" (seized) before consenting to the search	State: The interaction behind the nursery was a mere conversation and not a seizure; prior conduct need not convert it to a stop	Defendant: The extended, conspicuous pursuit into an isolated location plus convergence of two patrol cars and repeated questioning amounted to a stop	Court: The totality of circumstances shows a seizure—defendant reasonably would have believed she was not free to leave; suppression required

State v. Ashbaugh, 349 Or. 297 (establishes test for seizure under Ore. Const. art. I, § 9)
State v. Anderson, 354 Or. 440 (totality-of-circumstances; ‘‘show of authority’’ inquiry)
State v. Holmes, 311 Or. 400 (distinguishes mere conversation from a seizure)
State v. Backstrand, 354 Or. 392 (context and cumulative conduct can convert questioning into a stop)
State v. Moats, 251 Or. App. 568 (example where approach to parked car was not a seizure)
State v. Acuna, 264 Or. App. 158 (example where conduct escalated to a stop after repeated questioning and calling for backup)