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Sometimes an incline will put pressure on the Park movement or a sharp turned wheel at shut down. Best thing to do is yank up on the e-brake and then put it in park. For a sharp turned wheel, turn the wheel a tad more in the direction of the turn and pull it out of park as you do that.
If you do not have either of those situations, then you might have a solenoid in trouble in the console.
Also, a 2009 is a C6, this is the C7 forum, as Lisa mentioned.
It's supposedly caused by a bad limit switch, that will not energize the solenoid that releases the shifter locking pawl.
You can replace the limit switch, or tie back the locking pawl to eliminate the issue entirely.
Here is a PDF on tieing back the solenioid.
This is a pic of the wire pulled into the center console. The hole is drilled through the cashmere portion. I used plastic-coated picture-hanging wire.
This is a pic of the wire pulled into the center console. The hole is drilled through the cashmere portion. I used plastic-coated picture-hanging wire.