California, United States of America
The following excerpt is from People v. Sanchez, A126872 (Cal. App. 2011):
First, the evidence before us does not establish or even suggest that the spotlight was used for purposes of intimidation. The encounter occurred late at night in a residential area and the spotlight enabled both the officer and Sanchez to see better. Furthermore, relevant authority holds that the use of a spotlight may cause a reasonable person to believe he is "the object of official scrutiny." However, "such directed scrutiny does not amount to a detention." (People v. Perez (1989) 211 Cal.App.3d 1492, 1496; People v. Franklin (1987) 192 Cal.App.3d 935, 940.)
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