I was just looking at it again, ginger, and imo, the tree is in the grassy area, and not behind the car. Stoddard also mentioned the grassy area. Snipped from hearing transcript:
UNIDENTIFIED PROSECUTOR: When he parked how did he park? Did he pull straight into his space or something else?
STODDARD: When he pulls from the parking lot he pulls past the space. After he pulls past the space he goes into reverse and he backs up and when he backs up he backs up in between two cars that were parked in the row behind him and then he pulls forward into the parking space.
UNIDENTIFIED PROSECUTOR: And the parking space he pulls into, what, is to the left? If i am the person driving to the car, what is to my left?
STODDARD: If it's the person driving to your left it's another car.
UNIDENTIFIED PROSECUTOR: Is the driver side on the other side of the defendant's car?
STODDARD: No, the driver's side if we turn to your left you'll have a parked car and then the defendant's car and then to the right is a grassy area.
UNIDENTIFIED PROSECUTOR: OK, so the right is actually a grassy area with no cars or anything
STODDARD: Now did his car have a backing camera or anything like that that would have assisted him when he stopped, pulled back and backs up to pull in?
UNIDENTIFIED PROSECUTOR: Nothing that i could get to turn on.
STODDARD: So what would he have had to do to back up?
UNIDENTIFIED PROSECUTOR: He would have to look in the rear-view mirror and use both his side mirrors.
http://edition.cnn.com/TRANSCRIPTS/1407/03/wolf.02.html