State v. Parker, 337 P.3d 936

May 23, 2006: defendant, a passenger in a lawfully stopped pickup, was subjected to police questioning and information gathering after the stop for expired tags.
Officer Cioeta asked defendant about warrants, defendant denied, provided identifying information, which was entered and checked for warrants.
Another officer (Boman) had the truck driver and another passenger exit; the driver was cited, the other passenger arrested, and the truck was towed and inventoried.
Cioeta then asked defendant to get out of the truck, asked about weapons, and obtained consent to search after defendant denied weapon possession.
Defendant did not receive a statement that he was free to leave; the trial court denied suppression and defendant was convicted of carrying a concealed weapon.
On remand, the issue is whether the encounter constituted a seizure under Article I, § 9, given the totality of circumstances and prior decisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the encounter a seizure under Article I, §9?	Parker argues there was a show of authority restricting liberty.	Defendant contends the encounter was a seizure due to police domination and requests for information.	No seizure; totality shows no significant restraint.
Do asking for identification and warrant checks, without coercive conduct, amount to a seizure?	Parker asserts these steps create a seizure as part of ongoing investigation.	Defendant argues such requests are noncoercive and do not by themselves seize.	Not a seizure when considered separately; not coercive enough.
Do combined actions (getting out of vehicle, requests to search, and identification) create a seizure?	Parker contends the sequence shows suppression-worthy restraint.	Defendant contends actions, taken together, do not amount to a seizure.	In combination, still not a seizure; not significantly restraining.

State v. Ashbaugh, 349 Or 297 (2010) (rejected subjective stop test; standard for seizure defined by shows of authority)
State v. Parker, 355 Or 751 (2014) (remand decisions guiding seizure analysis; multiple Parker iterations)
State v. Highley, 354 Or 459 (2013) (limits on whether identification checks or probation status requests constitute seizure)
State v. Backstrand, 354 Or 392 (2013) (show of authority and seizure definitions; emphasis on totality of circumstances)
State v. Anderson, 354 Or 440 (2013) (seizure analysis under totality of circumstances; police actions considered cumulatively)
State v. Dudley, 245 Or App 301 (2011) (seizure analysis when police request information and obtain consent; distinctions in context)