Brown

A deputy sheriff investigating an emergency call of a fight in progress pulled his patrol car behind a parked vehicle and activated the emergency lights. Approaching the car, he saw defendant Shauntrel Ray Brown sitting behind the wheel, apparently intoxicated. We conclude Brown was detained when the emergency lights were activated. A reasonable person under the circumstances would not have felt free to leave and Brown submitted to the show of authority by remaining in his parked car. We further conclude that Brown’s brief detention was supported by reasonable suspicion. Accordingly, we affirm the Court of Appeal’s judgment.

I. BACKGROUND

About 10:37 p.m. on a Sunday night, the San Diego County Sheriff’s Department received an emergency call on its 911 line. The caller confirmed his address with the dispatcher and reported some people were fighting in an alley behind his home on Georgia Street in Imperial Beach. He could hear screaming and one person said, “the gun was loaded.” The following colloquy ensued:

The caller estimated that more than four people were involved, and said the participants lived two houses down from him on the same block. The dispatcher sent an…