vehicles. As mentioned in Starr, it is a settled proposition in California that a law enforcement vehicle can constitute “other traffic.” 222 Ariz. 65, ¶ 2, 213 P.3d at 221; see Logsdon, 79 Cal.Rptr.3d at 381. Other courts have reached the same conclusion. See State v. Seavey, 564 A.2d 388, 389 (Me.1989) (finding a police vehicle to constitute other traffic); State v. Heisler, 422 N.J.Super. 399, 29 A.3d 320, 328 (N.J.Super.Ct.App.Div.2011) (“ ‘Other traffic’ can include a police vehicle.”); State v. Hubble, 146 N.M. 70, 206 P.3d 579, ¶ 12 (2009) (finding a police vehicle to constitute other traffic); United States v. Burkley, 513 F.3d 1183, 1187 (10th Cir.2008) (finding a police vehicle to constitute other traffic); but cf. United States v. Mariscal, 285 F.3d 1127, 1132 (9th Cir.2002) (<HOLDING>). ¶ 13 In sum, based on the plain meaning of
holding automobile exeeption did not apply to warrantless search of vehicle where vehicle was not readily mobile because the vehicle was legally parked in parking lot occupants of vehicle were seated on a bench in the playground near the parking lot police officers surrounded the vehicle and the driver of the vehicle was handcuffed for safety purposes holding that the automobile exception does not apply to a vehicle that is parked immobile and unoccupied when police encounter it holding that police officer may order passengers to remain in vehicle with hands up during traffic stop holding on direct review that defendant was not in custody when he was interviewed by law enforcement officers in a parked police vehicle which was unmarked and unlocked holding that parked police vehicle could not constitute other traffic