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(1994); see generally OCGA § 17-4-20(a). Somesso argues that a law enforcement officer must use the least intrusive means to investigate criminal activity, see Holt v. State, 227 Ga.App. 46, 51 (487 S.E.2d 629) (1997) (Ruffin, J., concurring), and that Delatorre therefore should have executed the warrant before Williams entered the car. But Delatorre testified that he was alone when Williams left the apartment and entered Somesso’s car and that he called for backup while following them. Under the circumstances, Delatorre was not required to execute the warrant before Williams entered Somesso’s car.” 2. AUTOMOBILE PASSENGERS Mack v. State, 305 Ga.App. 697, 700 S.E.2d 685 (August 26, 2010). Defendant’s conviction for misdemeanor obstruction affirmed; contrary to defendant’s argument, officer had grounds to detain defendant, a passenger in a traffic stop, “because he believed Mack was drunk. And pursuant to OCGA § 40-6-95, ‘[a] person who is under the influence of intoxicating liquor or any drug to a degree which renders him a hazard shall not walk or be upon any roadway or the shoulder of any roadway.’” Arizona v. Johnson, 555 U.S. 323, 129 S.Ct. 781, 172 L.Ed.2d 694 (January 26, 2009). Arizona Court of Appeals erred in reversing defendant’s conviction for firearm possession by a convicted felon; officer’s detention of defendant, a passenger in a vehicle stopped for suspended registration, was authorized under the Fourth Amendment. “[I]n a traffic-stop setting, the first Terry condition – a lawful investigatory stop – is met whenever it is lawful for police to detain an automobile and its occupants pending inquiry into a vehicular violation. The police need not have, in addition, cause to believe any occupant of the vehicle is involved in criminal activity. To justify a patdown of the driver or a passenger during a traffic stop, however, just as in the case of a pedestrian reasonably suspected of criminal activity, the police must harbor reasonable suspicion that the person subjected to the frisk is armed and dangerous.” Based on Terry and Pennsylvania v. Mimms, 434 U.S. 106, 111, 98 S.Ct. 330, 54 L.Ed.2d 331 (1977) (per curiam) (“once a motor vehicle has been lawfully detained for a traffic violation, the police officers may order the driver to get out of the vehicle without violating the Fourth Amendment's proscription of unreasonable searches and seizures.”) ; Maryland v. Wilson, 519 U.S. 408, 415, 117 S.Ct. 882, 137 L.Ed.2d 41 (1997) (“an officer making a traffic stop may order passengers to get out of the car pending completion of the stop.”); and Brendlin v. California, 551 U.S. 249, 263, 127 S.Ct. 2400, 168 L.Ed.2d 132 (2007) (“a passenger is seized, just as the driver is, ‘from the moment [a car stopped by the police comes] to a halt on the side of the road.’”). “After Wilson, but before Brendlin, the Court had stated, in dictum, that officers who conduct ‘routine traffic stop[s]’ may ‘perform a “patdown” of a driver and any passengers upon reasonable suspicion that they may be armed and dangerous.’ Knowles v. Iowa, 525 U.S. 113, 117-118, 119 S.Ct. 484, 142 L.Ed.2d 492 (1998). That forecast, we now confirm, accurately captures the combined thrust of the Court's decisions in Mimms, Wilson, and Brendlin .” Arizona Appeals Court here erroneously concluded that encounter between defendant and officer was first-tier consensual encounter where defendant consented to exit car at officer’s request, and that officer therefore lacked articulable suspicion to detain defendant: “as stated in Brendlin, a traffic stop of a car communicates to a reasonable passenger that he or she is not free to terminate the encounter with the police and move about at will. See 551 U.S., at 257, 127 S.Ct. 2400. Nothing occurred in this case that would have conveyed to Johnson that, prior to the frisk, the traffic stop had ended or that he was otherwise free ‘to depart without police permission.’ Ibid. ” Remanded for consideration of whether officer had “reasonable suspicion that Johnson was armed and dangerous” such as to justify patdown, which revealed unlawful firearm possession. 3. BOLO – DESCRIPTION ADEQUATE Kinsey v. State, 326 Ga.App. 616, 757 S.E.2d 217 (March 27, 2014). Convictions for kidnapping with bodily injury and related offenses affirmed; trial court properly denied motion to suppress. Officer was able to observe sufficient information about defendant’s vehicle to match BOLO and justify stop. “Here, the evidence shows that the responding officer observed a silver vehicle turning right out of the complex at about the same time dispatch relayed the same information to him about the suspects' movements. The officer observed that the vehicle contained four black males wearing all black, which matched the description given by dispatch. The evidence also shows that at the time of the call, there was very little traffic on the roadway near the apartment complex. Based on the totality of these circumstances, the officers had the requisite articulable suspicion to justify the investigative stop. See Boone v. State, 282 Ga.App. 67, 70(2), 637 S.E.2d 795 (2006) (officer had the requisite articulable suspicion necessary to conduct a traffic stop shortly after receiving a be-on-the-lookout (‘BOLO’) describing the vehicle's color, number of occupants, road and direction of travel); McNair v. State, 267 Ga.App. 872, 874(1), 600 S.E.2d 830 (2004) (officer had an objective, reasonable suspicion of criminal activity to conduct a traffic stop of a car that matched description given in a BOLO alert and was traveling from the direction of the crime scene five minutes after the alert was issued).”

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