Cal SCT, over dissent of Liu, J., holds that police shining a spotlight on a parked car at night is a factor in whether the driver was seized (whether a reas person in that situation would feel free to leave), but isn't an automatic seizure. courts.ca.gov/opinions/docum… #N 
Liu, dissenting, would treat spotlight as imparting a message that you are not free to leave.
Liu's dissent has lots of cites to law review articles on how the Supreme Court has misapplied its own doctrine on seizures — most people wouldn't feel free to leave when the Supreme Court says a reasonable person would. Majority says, well, we are bound by SCOTUS, not articles.
FWIW, my own view is that the claim the SCT misapplied its test is missing the legal realist dimension here. The SCT has a set of situations in which they think a person is or is not seized. But they haven't come up with an abstract test that, so phrased, matches all the results.
A lot of academic articles focus on the last point, that the test isn't well-phrased, to say the Court's cases are wrong b/c they misapplied the test. But from a realist perspective, seems to me more useful to say the Court has a particular test they apply in a particular way.
Certainly may be that the results the Justices thought right on the facts of prior cases are problematic or wrong. And that the test is an awkward way to get there. But for lower courts, that's what you're stuck with, as the majority recognizes.
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