safeguards are not invoked. Id. Next on the escalating hierarchy of police-citizen encounters is “an investigatory stop.” See Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968). For a police officer to lawfully detain a citizen, “an investigatory stop requires a well-founded, articulable suspicion of criminal activity. Mere suspicion is not enough to support a stop.” Popple, 626 So.2d at 186. The third and final level of a police-citizen encounter “involves an arrest which must be supported by probable cause that a crime has been or is being committed.” Id. Greider, 977 So.2d at 792. It is well recognized that police officers may conduct welfare checks and that such checks are considered consensual encounters that do not involve constitutional implications. Id. (<HOLDING>); Dep’t of Highway Safety & Motor Vehicles v.
recognizing that officers making initial contact with driver of car who was lawfully parked late at night in a park was an appropriate welfare check where officer testified he was concerned because towels were obscuring the car windows holding that even if an officers stop of a defendant who was on foot was unlawful the search of a parked car was justified by a different officer observing a gun magazine in plain view in the car recognizing that emergency lights convey a signal that an officer approaching a car at night presents no threat to the occupant of the car holding that the driver of a car who had permission to use the car had standing to challenge its search holding that there was reasonable suspicion to stop an occupant of a parked car based on his presence late at night in an area known for drug activity his leaning over the car console with a faint light and his attempt to hide something upon seeing a police officer