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testified based upon his experience, was routinely subject to theft-related incidents. Both Taylor and the vehicle's driver appeared startled when they noticed the officer's presence and they immediately accelerated away and attempted to leave the scene. Finally, the officer testified that in his experience working with approximately 200 burglaries, burglary suspects are frequently discovered near the vicinity of the crime. Taken together, the above factors were sufficient to give the officer a particularized and objective basis for suspecting that Taylor and the vehicle's driver were or were about to be engaged in criminal activity.” Citing Cox (September 3, 2003), below; Distinguishing Winnie (February 3, 2000), below (“officer's observation that appellee's vehicle was parked behind a closed business during the early morning hours alone, without any report of criminal activity or other evidence of suspicious activity, was insufficient to justify the investigative stop”). Esposito v. State, 293 Ga.App. 573, 667 S.E.2d 425 (September 17, 2008). In defendant’s prosecution for possession of a weapon on school property, trial court properly denied defendant’s motion to suppress; stop was supported by articulable suspicion: “it was reasonable for the officer to infer, based on his training, experience, and common sense, that Esposito, who arrived with a companion long after the football game began and drove around slowly through the parking lot without parking in one of many empty spaces, was ‘casing’ the parking lot, looking to engage in criminal activity. The officer had been hired to secure the lot, specifically to guard against fighting, which was clearly a concern of the school. Under the totality of circumstances, the brief stop was neither arbitrary or harassing, but was based on a founded suspicion of criminal activity.” In re: E.C., 292 Ga.App. 798, 665 S.E.2d 896 (July 17, 2008). Delinquency adjudication upheld; juvenile’s actions amounted to obstruction. “[D]uring school hours, the officer was on routine patrol and looking for possible truants in an area known for having a high rate of burglaries when he observed several teenagers who appeared to be young enough to be subject to mandatory school attendance laws. Under these circumstances, the evidence supports a finding that the officer had a reasonable, particularized and objective basis for suspecting that the teenagers were truants. Thus, he was authorized to briefly stop and detain the teenagers while determining whether they were truants [fn] and, if so, to take custody of them and return them to school, pursuant to OCGA §§ 20-2-698 and 20-2-699.” “Moreover, given the other suspicious circumstances presented in this case, E.C.'s unprovoked flight when the officer approached provided additional support for the officer's suspicion that E.C. was involved in illegal activity, thereby further authorizing the officer to stop and briefly detain E.C. while he investigated the situation. See Copeland v. State, 281 Ga.App. 11, 14(2) (635 S.E.2d 283) (2006) (a defendant's unprovoked flight, when combined with other suspicious circumstances, can give rise to a reasonable, articulable suspicion of criminal activity).” Accord, In re: J.T., 297 Ga.App. 636, 678 S.E.2d 111 (April 29, 2009) (officers had grounds to stop known truant); Barber v. State , 317 Ga.App. 600, 732 S.E.2d 125 (September 11, 2012). State v. Martin, 291 Ga.App. 548, 662 S.E.2d 316 (May 16, 2008). Trial court properly granted defendant’s motion to suppress; officer lacked articulable suspicion to stop vehicle where he saw “flailing arms” and “what appeared to be ‘a pretty heated conversation’ between Martin and the female passenger.” “[Officer] Gurley testified that he stopped the car because he saw what appeared to be an argument, including flailing arms, in the cab of the pick-up truck. However, the stop was videotaped, and it is apparent from the recording that Gurley’s opportunity to view the altercation was fleeting at best. Although Gurley testified that he saw flailing arms, he did not say that he saw any blows being struck. And, as Gurley conceded on the stand, having an argument – even a heated argument – is not illegal .” Hinton v. State, 289 Ga.App. 309, 656 S.E.2d 918 (January 25, 2008). Officer was entitled to stop vehicle when he “saw the passenger throw a cigarette out of the car window. The officer stopped the car for littering, a violation of OCGA § 16- 7-43.” Lindsey v. State, 287 Ga.App. 412, 651 S.E.2d 531 (September 5, 2007). Officers had articulable suspicion of criminal activity justifying continued detention: defendants were detained at Dollar General store while suspected of attempting to pass counterfeit $100 bill. Bill was determined to be authentic, but officers continued detention on suspicion that defendants might possess drugs, based on agent’s “knowledge that at least one suspect had been previously arrested on methamphetamine charges, that those seeking to manufacture methamphetamine frequently shopped for supplies at stores such as Dollar General , and that the counterfeit case involved three suspects shopping together. Given his experience as a police officer in general and with drug enforcement specifically, Carroll also found suspicious Lindsey’s response upon being asked whether he had drugs or weapons in his truck. [“ Drugs? There ain’t no drugs in there.” ] While these circumstances might well be ‘susceptible to an innocent explanation, [they are] also consistent with illegal activity,’ and we therefore cannot say that the trial court erred in finding that they gave rise to a reasonable suspicion sufficient to

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