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justify an investigatory stop. [Cits.]” Resulting consent to search therefore was validly given. Note, no indication that defendants had purchased items used in making meth . Young v. State, 285 Ga.App. 214, 645 S.E.2d 690 (May 2, 2007). Habitual violator and false name convictions reversed. Trial court erred in denying defendant’s motion to suppress; stop was not supported by articulable suspicion. “[T]he only reason the officer stopped Young was because he saw him driving with a lawn mower in the car trunk near an area where there had been thefts reported. The officer, however, could not testify about any recent theft reports and admitted that he was not on the lookout for a stolen lawn mower. Moreover, there is no evidence that Young violated any traffic laws prior to the stop or that there was anything unlawful about him transporting a lawn mower in the trunk of a car.” Stop occurred after 1:30 a.m. Hayward El v. State, 284 Ga.App. 125, 643 S.E.2d 242 (February 16, 2007). Conviction for criminal reproduction of recorded material affirmed. “[T]he officer’s traffic stop of Hayward El’s vehicle was justified because he perceived that Hayward El was violating a local noise ordinance,” citing Hines v. State, 214 Ga.App. 476, 477 (448 S.E.2d 226) (1994). “Contrary to Hayward El’s argument, it is of no consequence to this inquiry whether he was ultimately cited for the noise ordinance violation. See Hines, supra, 214 Ga.App. at 478.” Accord , Jackson v. State , 297 Ga.App. 615, 677 S.E.2d 782 (April 23, 2009) (noise violation justified stop). Franklin v. State, 281 Ga.App. 409, 636 S.E.2d 114 (August 31, 2006). Convictions for possession of cocaine with intent to distribute, and related offenses, affirmed; trial court properly denied motion to suppress. “[Officer] Bradford’s observation of Franklin’s unusual, evasive behavior – coupled with his ensuing confrontation of Franklin in an area where a burglar alarm had been activated, followed by Franklin’s refusal or inability to respond to questions as to his conduct and whereabouts – provided a particularized and objective basis for suspecting that Franklin was engaged in wrongdoing, such that the officer’s attempt to undertake a weapons pat-down incident to a Terry -type investigative detention was neither arbitrary nor harassing. [Cits.]” Ward v. State, 277 Ga.App. 790, 627 S.E.2d 862 (February 28, 2006). In prosecution for possession of methamphetamine, trial court erred by denying defendant’s motion to suppress. Defendant’s meaningless lie to officer about her reason for being in parking lot did not, without more, give officer articulable suspicion for stop. “Officer Beltran specifically testified that he did not observe any conduct by Ward that caused him to suspect criminal activity. [Cit.] Moreover, her driver’s license was valid and she had no outstanding warrants. His only basis for continuing to question Ward was that she initially lied to him about her reason for being in the parking lot. We have held that an officer does not have reasonable, articulable suspicion of a crime when a person is merely nervous in police presence [Cit.] or stands in a known drug trafficking area in very cold weather for an hour. [Cit.] Similarly, we cannot find that Ward’s lie in this case authorized Officer Beltran to detain her. There is no evidence that Officer Beltran believed the lie itself related to criminal activity or that further investigation of the lie might yield evidence of criminal conduct. Rather, he was concerned by the mere fact that Ward had lied. Meaningless inconsistencies in answers to police questions, however, do not give rise to reasonable, articulable suspicion. [Cit.] Under these circumstances, Officer Beltran lacked a reasonable, articulable suspicion that would justify a second-tier encounter.” Abrogated by Salmeron v. State , 280 Ga. 735, 632 S.E.2d 645 (July 13, 2006), see Hayes v. State , 292 Ga.App. 724, 665 S.E.2d 422 (July 15, 2008). Accord, Matthews v. State , 330 Ga.App. 53, 766 S.E.2d 515 (November 21, 2014) (Physical precedent only) (Inconsistencies in Matthews’s explanations for the lack of luggage in his car on his trip were meaningless and did not “give rise to reasonable, articulable suspicion” for a drug investigation). Compare Jackson (February 9, 2016), above (defendant’s inconsistent answers to questions about where he had been, where he was going, etc., provided articulable suspicion to extend traffic stop). Castleberry v. State, 275 Ga.App. 37, 619 S.E.2d 747 (August 9, 2005). Physical precedent only. Methamphetamine possession and related convictions reversed on other grounds. During routine traffic stop, officer saw shotgun with sawed- off barrel protruding from under seat. “[Officer] … asked Castleberry if he had any other weapons in the truck, and Castleberry responded ‘that he didn’t know.’ Thus, [officer] searched the vehicle that contained only the one shotgun, which had a sawed-off barrel. OCGA § 16-11-122 provides that ‘[n]o person shall have in his possession [a] sawed-off shotgun,’ which is defined as a shotgun ‘having one or more barrels less than 18 inches in length or if such weapon as modified has an overall length of less than 26 inches.’ [Cit.] According to [officer], he was not sufficiently familiar with the relevant code section to determine whether the gun was legal. But he claimed that he and the other officers ‘felt like that by just looking at [the gun] without measuring it ... that it fell within the length that would make it a sawed-off shotgun.’ Castleberry was thus charged with possessing a sawed-off shotgun, but when the gun was measured at the