☢ test - Í

that Folsom’s pre-Miranda statements had to be suppressed.” Accord, Lengsfeld v. State , 324 Ga.App. 775, 751 S.E.2d 566 (November 18, 2013) (defendant’s subjective belief as to whether he’s in custody not dispositive). Tolbert v. State, 300 Ga.App. 51, 684 S.E.2d 120 (September 9, 2009). Statement was not custodial: “The officers asked Tolbert, who was there, to accompany them to the Clayton County Police Department to answer a few questions. Tolbert asked whether he was under arrest and a detective told him that he was not. Due to officer safety reasons, Tolbert rode in the back seat of the detective's unmarked police car, seated next to another detective, to the police station. Tolbert's girlfriend followed the detective's car to bring him home after the interview. Tolbert did not ask to ride to the station with his girlfriend, was not handcuffed, and did not protest about riding in the police vehicle.” Carter v. State, 285 Ga. 394, 677 S.E.2d 71 (April 28, 2009). Defendants were not in custody when statements made. “[I]nvestigators received information that on the night of the crimes [defendants] had been at the victim's home. An investigator called [defendants] and asked if they would come to the Jones County Sheriff's Department for an interview. [Defendants] agreed, but when they had not arrived after an hour, the investigator called again and asked if they needed a ride. James Carter told the investigator they were south of Warner Robins because a friend had died, and arrangements were made for [defendants] to go to the Houston County Sheriff's Office because it was closer to their location. [Defendants] arrived at the station first, waiting in the parking lot until Jones County investigators arrived. Investigators then informed [defendants] that they were free to leave but invited them into the sheriff's office to talk. Accordingly, the evidence showed that [defendants] were not under formal arrest at any time during their interviews and were told by investigators prior to the interviews that they were free to leave.” Gray v. State, 296 Ga.App. 878, 676 S.E.2d 36 (March 24, 2009). Trial court properly denied motion to suppress defendant’s statement. Defendant was not under arrest although officers ordered him off his mother’s couch and handcuffed him; “rather, the record shows that Gray was placed in investigatory detention at that point for valid officer safety reasons.” Officers were investigating armed robbery of defendant’s next door neighbors, and followed his footprints to his door. “An ‘officer must make quick decisions as to how to protect himself and others from possible danger,’ Jackson v. State, 236 Ga.App. 492, 495(2) (512 S.E.2d 24) (1999), and the officer is not required to risk his life in order to effectuate an investigatory detention. Holsey [ v. State, 271 Ga. 856, 861(6) (524 S.E.2d 473) (1999)]. Mindful of these principles, we have held that in sufficiently dangerous circumstances, officers may handcuff a suspect as part of an investigatory detention without transforming the detention into a de facto arrest. See Jackson, 236 Ga.App. at 495(2). We conclude that the circumstances of the present case were sufficiently dangerous to justify the officers in handcuffing Gray as part of his investigatory detention,” especially since “the armed robbery had been an extremely violent one in which the victim had been threatened and beaten badly with a firearm.” Escobar v. State, 296 Ga.App. 898, 676 S.E.2d 291 (March 24, 2009). Trial court properly admitted defendant’s statement during traffic stop, “there’s nothing in the car, search it;” traffic stop was not an arrest. “Escobar argues that this general rule does not apply because, given that the stop was made for the express purpose of detaining and/or arresting him, he was in custody from the time it began. This argument, however, ignores the fact that ‘whether the police had probable cause to arrest and whether the defendant was the focus of the investigation are irrelevant considerations for Miranda purposes.’ State v. Folsom, 285 Ga. 11, 673 S.E.2d 210 (February 9, 2009). Additionally, ‘the subjective views of the interrogator and suspect are not dispositive of whether a person is in custody for the purposes of Miranda warnings.’ Folsom, supra, slip op. at 5.” Accord, State v. Lupuloff , 301 Ga.App. 513, 687 S.E.2d 861 (November 17, 2009). Ellison v. State, 296 Ga.App. 752, 675 S.E.2d 613 (March 19, 2009). Trial court properly found that statement was non- custodial when made “in [defendant’s] office, sitting behind his desk.” Solano-Rodriguez v. State, 295 Ga.App. 896, 673 S.E.2d 351 (February 10, 2009). Trial court properly denied motion to suppress defendant’s statements; bus passenger was not in custody when officer asked if bag belonged to him, then asked for consent to search it. Statements here consisted of answering “yes” to both questions. Fact that officers stopped bus on interstate for random safety check did not place interstate passengers in “custody” for Miranda purposes. State v. Folsom, 285 Ga. 11, 673 S.E.2d 210 (February 9, 2009). Trial court’s grant of defendant’s motion to suppress reversed; trial court used an outdated test for determining whether defendant was in custody. Disapproves Shy v. State, 234 Ga. 816, 821 (218 S.E.2d 599) (1975), and its progeny, specifically State v. Wilson, 257 Ga.App. 120, 126 (570 S.E.2d 409) (2002) and State v. Hendrix, 221 Ga.App. 331(1) (471 S.E.2d 277) (1996), and the subjective four-part test