I don't think that the officer who was hit was to the side of the car at all. I think he was standing in front of the car and may have been to the left of center line. A car has a front, back and two sides. You can't be standing on one side and the front at the same time.
if you are ten feet in front of a car and 3 feet off to the side you can accurately be described as both in front of the car and to the side of it.
to nobody in particular - please dont waste time taking my completely made up example and comparing it to the facts in this case, it is a hypothetical example used to make a theoretical point. thanx.