United States v. Carr, 674 F.3d 570

Officers patrolling a high-crime area observed Carr's white Tahoe at a coin-operated carwash bay; carwash activity was minimal and the car was not being washed.
The carwash was alleged to be a meeting place for illegal narcotics transactions; officers observed the car in the bay on two occasions with no washing.
Officers parked at an angle near the Tahoe, activated blue lights briefly to identify themselves, and then approached Carr on foot.
Carr exited the Tahoe after a consensual pat-down; officers observed marijuana on the console, then arrested him and searched the car.
A district court denied suppression after evidentiary hearings; on remand, the court again denied suppression; Carr appealed challenging the encounter as unlawful—this court affirmed, holding the encounter was consensual or, at most, supported by reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the initial encounter was consensual	Carr argues the stop was a seizure and coercive	Carr's position that officers' approach and blocking posture transformed into seizure	Encounter was consensual; no seizure at initial approach
Whether reasonable suspicion justified detaining Carr	Carr contends no reasonable suspicion existed	Government argues high-crime area, carwash as drug-meeting site, and vehicle status created suspicion	Yes; totality of circumstances supported reasonable suspicion to stop
Did brief use of blue lights convert encounter into seizure	Any use of lights indicates compulsion	Lights were merely for identification and not coercive	No; lights were noncoercive and did not convert encounter into seizure
Whether the time-of-day and location factors were enough to support suspicion	Carr asserts factors were insufficient alone	These factors, with the informant tip, supported suspicion	Yes; combined with location and timing under totality of circumstances supported detention

United States v. See, 574 F.3d 309 (6th Cir. 2009) (consent/egress not blocked equals consensual encounter; but see later)
United States v. Gross, 662 F.3d 393 (6th Cir. 2011) (high-crime area alone not enough for suspicion; community caretaking distinction)
United States v. Dingess, 411 Fed.Appx. 853 (6th Cir. 2011) (unpublished; approaching vehicle from two sides can still be consensual)
United States v. Davis, 430 F.3d 345 (6th Cir. 2005) (furtive movements plus contraband observed can supply suspicion)
United States v. See (see above), 574 F.3d 309 (6th Cir. 2009) (see above)