written findings of fact, in which the court wrote that Sgt. Norman "rapped on the driver's side window and requested that the window be rolled down.” According to the State, this constitutes a finding that Sgt. Norman's communication was a request, not an order. The court’s very next sentence, and its comments at the hearing, make it clear that the court determined that the “request” was, in fact, an order that Patterson reasonably believed he could not ignore. 5 . Other courts confronting similar facts have come to differing conclusions. See Borowicz v. North Dakota Dep’t of Transp., 529 N.W.2d 186, 188 (N.D.1995) (stating that stop arguably occurred when officer's instruction to open the door could be interpreted as an order); Ebarb v. State, 598 S.W.2d 842, 850 (Tex.Crim.App.1979) (<HOLDING>); but see Akins v. State, 266 Ga.App. 214, 596
holding that officers order to roll down window or open door creates a temporary seizure holding a car was broken into or entered when defendant reached in through the open window of a car holding that it was unreasonable for officers to break down doors that they already knew were open holding that an unconstitutional seizure occurred when police officers discovered that a suspect illegally sold alcohol from his home and ordered him to open the door involuntarily to be arrested inside his home holding that if a residents decision to open his door to police is made involuntarily a seizure within his home has occurred