State v. Steffes, 791 N.W.2d 633

Steffes was parked in a Brass Rail bar parking lot at about 2:00 a.m. and was in a non-running car with the dome light on and radio loud.
Officer Craig tapped on the window, asked Steffes to lower the window, and repeatedly tried to engage him.
Steffes provided a false name and false birth date when questioned about his identity.
Steffes claimed he did not have a driver’s license; he exited the car and W Meisch asked him to return to the vehicle.
Steffes was charged with providing false information or a false report to a law enforcement officer, and moved to suppress the evidence on Fourth Amendment grounds.
The district court denied suppression, Steffes pled conditional guilty under North Dakota Criminal Procedure Rule 11, and appealed the suppression ruling; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Steffes was seized in violation of the Fourth Amendment	Steffes (Steffes) argues the officer’s repeated knocking and requests amounted to a seizure.	Craig’s actions were not a seizure; there was no command or show of authority compelling compliance.	Not a seizure; officer’s actions were reasonable and did not compel Steffes to respond.

State v. Graf, 721 N.W.2d 381 (ND 2006) (defers to district court findings on suppression and reviews legal standards de novo)
State v. Woinarowicz, 720 N.W.2d 635 (ND 2006) (credibility and weight of evidence; standard of review for suppression decisions)
Goebel v. State, 725 N.W.2d 578 (ND 2007) (relates to Fourth Amendment seizure standards and reasonable suspicion)
Abernathey v. Dep’t of Transp., 768 N.W.2d 485 (ND 2009) (approach to a parked vehicle; knocking and talking does not always seize,)
City of Mandan v. Gerhardt, 783 N.W.2d 818 (ND 2010) (officer approach in public place and conversational engagement not a seizure)
City of Jamestown v. Jerome, 639 N.W.2d 478 (ND 2002) (conversational approach to a person in a parked vehicle does not constitute seizure)