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flight upon seeing the police car, we conclude that the evidence established probable cause for the warrantless arrest.” Accord, Brooks v. State , 324 Ga.App. 352, 750 S.E.2d 423 (October 25, 2013) (flight in connection with other circumstances supports probable cause for arrest). State v. Batty, 259 Ga.App. 431, 577 S.E.2d 98 (February 4, 2003). DUI arrest lacked probable cause where only evidence of intoxication was odor of alcohol on breath. Trial court, in its discretion, could find minor traffic offenses (improper right turn on red, following too closely) either not alcohol-related or not credible. Ayres v. State, 259 Ga.App. 290, 576 S.E.2d 597 (January 13, 2003). “Ayres’ contention that he was taken into custody when the sergeant placed him in his patrol car must… fail because the evidence, viewed in a light most favorable to the trial court's ruling, shows that Ayres was put in the car only for his own safety and not because he was under arrest. The sergeant testified unequivocally that he did not arrest Ayres, that he put Ayres in the car only to protect him from [the other driver in the accident, who had already slugged him once], that he did not put handcuffs on Ayres, and that there were handles on the car doors so Ayres could have gotten out of the car. Moreover, given that he was involved in a motor vehicle collision involving serious injuries, Ayres was legally obligated to remain at the scene.” Also, other driver’s assault did not amount to a citizen’s arrest because “assault entailing unreasonable force is not a legitimate citizen's arrest because only force that is reasonable under the circumstances may be used to restrain individual arrested.” Buchanan v. State, 259 Ga.App. 272, 576 S.E.2d 556 (December 17, 2002). Conviction for cocaine possession affirmed; trial court properly denied motion to suppress. “A radio transmission that confirms an outstanding warrant establishes the necessary probable cause to arrest. Although insufficient to authorize conviction, NCIC printouts have been held reliable enough to support a ‘reasonable belief which is needed to establish probable cause for arrest.’ Probable cause to arrest Buchanan existed once the officer learned of the warrant. Buchanan’s arrest was therefore lawful. Id. Whether or not the information about the warrant later proved incorrect or invalid is immaterial.” Accord, Howard (June 15, 2005), above; Lucas (March 22, 2007), and cases collected thereunder. Mercer v. State, 251 Ga.App. 465, 554 S.E.2d 732 (September 6, 2001). Drug possession convictions reversed. State could not justify the detention and search of Defendant’s person under OCGA § 17-5-28(2), as the officers lacked probable cause to handcuff and search Defendant while executing a search warrant at another person’s home. Defendant was not named in the search warrant, was outside of the house when officers arrived and did not make any threatening gestures or appear to be armed and dangerous. Atwater v. Lago Vista, 532 U.S. 318, 121 S.Ct. 1536, 149 L.Ed.2d 549 (April 24, 2001). Gail Atwater was stopped in 1997 for allowing her two children, ages 3 and 5, to ride without their seatbelts on, a charge that can bring a fine (but no jail sentence) in Texas. Instead of writing the mother a ticket, the police officer arrested her, put her in handcuffs and took her to jail. Atwater sued the city and police, claiming that her Fourth Amendment right to be free from unreasonable seizures was violated. Held, an officer may arrest anyone when probable cause exists to believe that a suspect is committing an offense. Police have the power to make arrests for misdemeanors that are punishable only by a fine, and not by jail time. Query: Does the same result obtain under the Georgia Constitution? See Durden v. State, 250 Ga. 325, 297 S.E.2d 237 (1982) (stating general rule that “an arrest and search, legal under federal law, are legal under state law”). State v. Jones, 245 Ga.App. 763, 538 S.E.2d 819 (August 31, 2000). In drug prosecution, trial court properly granted motion to suppress; officers’ detention of defendant following traffic stop over her objection amounted to arrest without probable cause. After issuing warnings for traffic violations, officer asked to search defendant’s car; defendant declined to consent, said she was in a hurry to get to work, and told officer he’d have to get a warrant. She did offer, however, for officer to search her parked car while she went inside to work, but officer insisted she stay with the vehicle. Officer instead called for drug dog. It took about three minutes for the drug dog to arrive, then another 15-20 for a supervisor to observe the dog, per department policy. 1. Detention was an arrest. “In this case, the detention was more than a mere investigative stop requiring only reasonable suspicion. Jones had arrived at work, parked her car, and was attempting to report for work. She told the officer she was late for work and that he could search her parked car while she was at work. Thus, there was no rapidly developing situation which would justify detaining Jones. Furthermore, since the drug dog and his handler were already on the scene, despite any departmental rule to the contrary, police could have conducted the free- air search while the officer was issuing warnings for the traffic offenses. Such a procedure would have quickly confirmed or dispelled the officer's suspicions. The officer acted unreasonably in failing to recognize or pursue the less intrusive means of accomplishing his objective. “See Alex v. State, 220 Ga.App. 754, 756(2), 470 S.E.2d 305 (1996).” We agree with the trial court that, in requiring Jones to wait for the supervisor to arrive before the free-air search began, police