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required by OCGA § 37–3–41, and it is undisputed that Boatright had not committed, nor was he suspected of committing, a penal offense as mandated by OCGA § 37–3–42(a). FN15. We reject the State's position that the police department's standard operating procedures gave the officers the authority to take Boatright into custody that the statutory law otherwise did not.” “[A]ny seizure of a person—even the taking of a person into civil custody [ See Lindsey v. State, 282 Ga.App. 644, 646–47, 639 S.E.2d 584 (2006) (distinguishing between a civil custody authorized by the mental-health code and a criminal arrest). ] — is governed by the Fourth Amendment to the United States Constitution [ See Soldal v. Cook County, 506 U.S. 56, 67(II), 113 S.Ct. 538, 121 L.Ed.2d 450 (1992) (recognizing that the protection afforded by the Fourth Amendment ‘applies in the civil context as well’ as in the criminal context); accord New Jersey v. T.L.O., 469 U.S. 325, 334–335, 105 S.Ct. 733, 83 L.Ed.2d 720 (1985); Michigan v. Tyler, 436 U.S. 499, 504–506, 98 S.Ct. 1942, 56 L.Ed.2d 486 (1978); Marshall v. Barlow's, Inc., 436 U.S. 307, 312–313, 98 S.Ct. 1816, 56 L.Ed.2d 305 (1978); Camara v. Municipal Court of San Francisco, 387 U.S. 523, 528, 87 S.Ct. 1727, 18 L.Ed.2d 930 (1967); Braddock v. State, 127 Ga.App. 513, 515, 194 S.E.2d 317 (1972); see also O'Connor v. Ortega, 480 U.S. 709, 715(II), 107 S.Ct. 1492, 94 L.Ed.2d 714 (1987) (‘[B]ecause the individual's interest in privacy and personal security suffers whether the government's motivation is to investigate violations of criminal laws or breaches of other statutory or regulatory standards, ... it would be anomalous to say that the individual and his private property are fully protected by the Fourth Amendment only when the individual is suspected of criminal behavior.’ (punctuation omitted)); McCabe v. Life–Line Ambulance Serv., Inc., 77 F.3d 540, 544(II)(C) (1 st Cir., 1996) (‘Included among the civil proceedings in which the Fourth Amendment applies are involuntary commitment proceedings for dangerous persons suffering from mental illness.’); Lenz v. Winburn, 51 F.3d 1540, 1547(IV)(A)(2) (11 th Cir., 1995) (‘[T]he right against unreasonable seizures would be no less transgressed if the seizure was undertaken to collect evidence, verify compliance with a housing regulation, effect an eviction by the police, or on a whim, for no reason at all.’) (punctuation omitted). ] and Article I, Section I, Paragraph XIII of the Georgia Constitution. [ Ga. Const. Art. I, § 1, ¶ XIII (‘The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures shall not be violated; and no warrant shall issue except upon probable cause supported by oath or affirmation particularly describing the place or places to be searched and the persons or things to be seized.’). ] and specifically, when an officer takes a PERSON INTO CUSTODY FOR AN involuntary mental-health examination, the seizure must be supported by probable cause. [Cits.] In this context, probable cause exists only if ‘there are reasonable grounds for believing that the person seized is subject to seizure under the governing legal standard.’” 4. GENERALLY Jackson v. State , 243 Ga.App. 289, 531 S.E.2d 747 (March 17, 2000). Armed robbery and related convictions affirmed; defendant’s claim that he was illegally arrested presents no ground for reversal absent any claim that evidence was improperly seized as a result. “‘Assuming the arrest to have been illegally made, there is no claim that the conviction rested upon evidence seized as a result of the illegal arrest, or upon a confession secured pursuant to the illegal arrest, etc., but simply that he was illegally arrested. This, alone, does not entitle defendant to release or a new trial.’ Johnson v. State, 128 Ga.App. 69, 70(2), 195 S.E.2d 676 (1973).” 5. PRETEXTUAL ARREST/ULTERIOR MOTIVES See also subheading ARTICULABLE SUSPICION FOR STOP/ TERRY STOPS – PRETEXTUAL STOP/ULTERIOR MOTIVE, below Arkansas v. Sullivan, 532 U.S. 876, 121 S. Ct. 1876, 149 L.Ed.2d 994 (May 29, 2001). Reversing Arkansas Supreme Court, which erroneously affirmed suppression of evidence resulting from traffic stop based on police officer’s subjective intent/ulterior motive to search for drugs when he arrested defendant on traffic offenses. Officer stopped defendant for speeding and improper windshield tint. Upon seeing his license, officer recognized that he had heard defendant’s name in relation to drugs. Noticing “a rusted roofing hatchet on the car's floorboard. [Officer] Taylor then arrested Sullivan for speeding, driving without his registration and insurance documentation, carrying a weapon (the roofing hatchet), and improper window tinting.” Arkansas Supreme Court improperly “affirmed the trial judge's suppression of the drug-related evidence on the theory that Officer Taylor's arrest of Sullivan, although supported by probable cause, nonetheless violated the Fourth Amendment because Taylor had an improper subjective motivation for making the stop. The Arkansas Supreme Court's holding to that effect cannot be squared with our decision in Whren [ v. United States, 517 U.S. 806, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996)] , in which we noted our ‘unwilling[ness] to entertain Fourth Amendment challenges based on the actual motivations of individual officers,’ and held unanimously that ‘[s]ubjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis.’ 517 U.S., at 813, 116 S.Ct. 1769.” 6. PROBABLE CAUSE Williams v. State, S15A1857, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 462667 (February 8, 2016). Felony murder and related convictions affirmed. “Contrary to appellant’s assertions, there is no requirement that an affidavit in