☢ test - Í
Cray v. State, 291 Ga.App. 609, 662 S.E.2d 365 (May 21, 2008). BOLO was sufficient to justify stop in relation to convenience store robbery: “The vehicle description in this case was much more particularized than that in Vansant. It included the make and model of the car, its body color, its roof color, its large size, and a description of the wheels. The robbery occurred at 8:19 p.m., the victim described the suspect at 8:39 p.m., and the vehicle was stopped at 8:49 p.m., thirty minutes after the robbery. Additionally, Cray matched the victim’s detailed description of the robber. The traffic officer first spotted Cray on a street connecting to the street where the robbery took place and appeared to be familiar to the victim and the police officers. ‘ Given the [vehicle’s] description and proximity to the crime, the officer had a well-founded, objective basis for suspecting the occupant [ ] of the [vehicle was] the subject [ ] of the lookout.’ Givens v. State, 218 Ga.App. 415, 417(1) (461 S.E.2d 579) (1995); see also McNair v. State, 267 Ga.App. 872, 874(1) (600 S.E.2d 830) (2004).” Accord, Ansley v. State , 325 Ga.App. 226, 750 S.E.2d 484 (November 18, 2013) (“police had a detailed description of the car including its make, color, approximate age, and features such as tinted windows and rims. A deputy was able to locate the car within 45 minutes after a BOLO was put out, at a location within two miles of the robbery that could be easily reached on main roads in the direction the vehicle was last seen traveling.”). Grandberry v. State, 289 Ga.App. 534, 658 S.E.2d 161 (February 7, 2008). Police had articulable suspicion for stop based on BOLO: “a caller to Thomas County 911 identifying himself as Rasheed Johnson reported that Michael ‘Cranberry’ had attempted to rob him at a Grady County establishment known as Johnson’s Meat Market. Based on the information relayed by the caller, the Thomas County dispatch issued a be on the lookout (‘BOLO’) for a black Neon with New York licence plates being driven by a black male and heading toward Thomasville. According to the BOLO, the suspect was carrying a shotgun and narcotics.” Police found and stopped the described vehicle. Held, this info was sufficient to authorize stop, although the police were later unable to locate the caller and take his statement and defendant’s later arrest was ruled unsupported by probable cause. “Grandberry argues that because the complainant was never found, the police had received information from the equivalent of an anonymous tipster whose statements demonstrated only knowledge of current public information and therefore lacked sufficient indicia of reliability to establish reasonable suspicion of Grandberry’s criminal activity. See Florida v. J.L., 529 U.S. 266, 270-271(II) (120 S.Ct. 1375, 146 L.Ed.2d 254) (2000) (anonymous tip that a young man standing at a particular bus stop and wearing a plaid shirt was carrying a gun contained no predictive information and so lacked indicia of reliability to establish reasonable suspicion). Although the complainant’s reliability was subsequently put into question when he failed to meet police at the agreed upon location, ‘[t]he reasonableness of official suspicion must be measured by what the officers knew before they [made the stop].’ Id. at 271(II). See McDaniel v. State, 227 Ga.App. 364, 366(2) (489 S.E.2d 112) (1997) (existence of a reasonable suspicion to stop a moving vehicle must be measured by current knowledge and not hindsight). At the time Grandberry was stopped, police had reason to believe they had received information from an identified victim who was on his way to the crime scene to meet with police officers, and not an anonymous tip. Accordingly, we conclude that police had acquired reasonable suspicion that Grandberry was involved in an attempted robbery and were justified in detaining him in order to confirm his identity and to maintain the status quo while conducting further investigation of the alleged crime. See Lamb v. State, 269 Ga.App. 335, 337 (604 S.E.2d 207) (2004) (police had reasonable suspicion to suspect defendant of criminal activity based on bartender’s call to 911); State v. McFarland, 201 Ga.App. 495, 496 (411 S.E.2d 314) (1991) (‘[w]e have no hesitation in concluding that [the officer], upon hearing a radio report that an identified person has observed an intoxicated person driving away in a described car, had reasonable grounds for stopping [defendant’s] car based on his founded suspicion that the law against driving while intoxicated was being violated’).” Lacy v. State, 285 Ga.App. 647, 647 S.E.2d 350 (June 4, 2007). Stop based on BOLO was supported by articulable suspicion: “In this case, the undisputed evidence shows that, before the deputy stopped Lacy’s truck, he knew that there had been a domestic dispute in the Calousa Lake subdivision, that the man involved may have been drinking, and that the man had just left his house in a red pickup truck and was driving toward the exit to the subdivision. Within two to three minutes of being notified that Lacy had left his house, the deputy turned into the subdivision and immediately encountered a red pickup truck leaving the subdivision. Upon seeing the deputy’s patrol car with its blue flashing lights, the driver of the truck pulled to the side of the road and stopped. The recording from the deputy’s patrol car also shows that there were very few vehicles on the road in that area during the deputy’s eight minute drive toward Lacy’s house following the domestic dispute call. In fact, the deputy encountered only ten other vehicles on the road during the first six minutes, and none within the two minutes before he encountered Lacy at the entrance to the subdivision.” Boone v. State, 282 Ga.App. 67, 637 S.E.2d 795 (October 24, 2006). Armed robbery conviction affirmed; trial court properly denied motion to suppress. Dispatched look-out gave articulable suspicion for stop: “the responding officer turned on his blue lights and stopped [defendant’s] truck upon hearing a recent BOLO that described the truck’s color, number of occupants, road of travel, and direction of travel. ‘This detailed information provided the [officer] with the
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