Williams v. State (1997)

See, e.g., Gentles v. State, 50 So.3d 1192, 1197 (Fla. 4th DCA 2011) (holding consensual encounter became a stop when the officer directed the defendant to shut off car’s engine as this “constituted a show of authority which restrained the defendant’s freedom of movement”); Williams v. State, 694 So.2d 878, 880 (Fla. 2d DCA 1997) (finding officer’s instructing defendant to pull waistband of his pants forward converted consensual encounter into a stop).

Williams v. State, 694 So.2d 878, 879 (Fla. 2d DCA 1997).

Popple v. State, 626 So.2d 185, 188 (Fla.1993) (stating that "[w]hether characterized as a request or an order" the act of directing a person to exit his vehicle "constituted show of authority ... because a reasonable person under the circumstances would believe that he should comply"); Williams v. State, 694 So.2d 878, 880 (Fla. 2d DCA 1997) (holding that while initial questions as to what defendant was doing behind a closed bar were permissible, subsequent request that def…

See, e.g., Williams v. State, 694 So.2d 878, 880 (Fla. 2d DCA 1997).

See State v. Poole, 730 So.2d 340, 342 (Fla. 3d DCA 1999); see also Williams v. State, 694 So.2d 878, 880 (Fla. 2d DCA 1997) (holding that while initial questions as to what defendant was doing behind a closed bar were permissible, subsequent request that defendant pull his waistband forward converted consensual encounter into detention).

See State v. Poole, 730 So. 2d 340, 342 (Fla. 3d DCA 1999); see also Williams v. State, 694 So. 2d 878, 880 (Fla. 2d DCA 1997) (holding that while initial questions as to what defendant was doing behind a closed bar were permissible, subsequent request that defendant pull his waistband forward converted consensual encounter into detention).

See Williams v. State, 694 So.2d 878 (Fla. 2d DCA 1997)(finding that officer's request that defendant pull his waistband forward converted consensual encounter to stop); Johnson v. State, 610 So.2d 581 (Fla. 1st DCA 1992)(holding that officer's instructing the defendant to remove his hands from his pockets and to turn around so that he could look at him rendered contact with police a stop).

See also Williams v. State, 694 So.2d 878 (Fla. 2d DCA 1997) (inquiry focuses on whether officer’s actions have communicated to a reasonable person that he or she is not free to leave).

See Williams v. State, 694 So.2d 878 (Fla. 2d DCA 1997)(concluding initial encounter between police and defendant and preliminary questioning was consensual encounter until officer asked defendant to pull his waistband forward, at which point consensual encounter became investigatory stop.) Analyzing the facts in Lang, 671 So.2d at 294 , the court observed: ... this case turns on whether Lang had submitted to the deputy's authority at the time he dropped the pill bottle....

See Williams v. State, 694 So.2d 878 (Fla. 2d DCA 1997)(concluding initial encounter between police and defendant and preliminary questioning was consensual encounter until officer asked defendant to pull his waistband forward, at which point consensual encounter became investigatory stop.) Analyzing the facts in Lang, 671 So.2d at 294 , the court observed:, ... this ease turns on whether Lang had submitted to the deputy’s authority at the time he dropped the pill bottle....