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found in the bag, contending the stop of the car was not supported by a reasonable articulable suspicion. Held, the trial court properly denied the motion for two reasons: first, there was no unconstitutional seizure because a fleeing suspect has not been seized (citing California v. Hodari D. , 499 U.S. 621, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991)); second, Defendant had no expectation of privacy in an item he discarded. “Stopping the car did not amount to the seizure of his person under the facts presented, and the bag of drugs was not found in the car.” Thus, the evidence is admissible even if the stop was not supported by reasonable suspicion of criminal activity. Holmes v. State, 252 Ga.App. 286, 556 S.E.2d 189 (November 2, 2001). Drug convictions reversed; trial court erred by denying motion to suppress. One night, on the way to patrol a shopping center, two detectives, wearing vests identifying them as police, drove their unmarked car into an area known for high drug activity. Driving through this area, they observed Defendant walk from a parked black car to a red car. After turning their car around, the detectives observed the red car drive away. As the detectives drove down the street, Defendant walked around their car and approached the passenger side. A detective asked Defendant, “What’s up?” and Defendant replied, “Not much,” and walked away. The detective asked Defendant if everything was okay and Defendant affirmatively answered while continuing to walk away. Defendant, who was approaching an apartment complex, changed direction and walked back towards the black car. Having witnessed no criminal activity by Defendant, the detectives drove away, checked a nearby shopping center and then returned, a couple of minutes later, to where they had observed Defendant. Defendant was sitting in the black car, which was covered in mud and looked as though it had not been driven for some time. The detectives pulled up to the car and activated their blue lights. Exiting their vehicle, the detectives asked Defendant to exit the car in which he was sitting. One of the detectives then did a pat-down search of Defendant which revealed a glass pipe in his pocket containing cocaine residue. Held, while Defendant’s behavior might justify close observation, it is not alone sufficient to indicate that Defendant was or might have been engaged in illegal activity so as to provide a reasonable, articulable suspicion to stop Defendant. Cited in Franklin (August 31, 2006), above. Berry v. State, 248 Ga.App. 874, 547 S.E.2d 664 (March 30, 2001). Interlocutory appeal in drug prosecution. Officer stopped defendant’s vehicle because it had a dealer drive-out tag. Officer’s stated reason for stop was to check to see if the car was stolen. This was not a particularized and objective basis for suspecting the particular person stopped of criminal activity (although a stop to enforce motor vehicle registration laws would have been). State v. Causey, 246 Ga.App. 829, 540 S.E.2d 696 (October 31, 2000). In prosecution for drug and weapons charges, trial court erred in granting motion to suppress. The officers noticed an unknown man entering a parking lot on foot from a nearby hotel who appeared to be wandering around the lot, walking between the parked cars and stopping to look inside them. Held, the arresting officers had reason to believe that the defendant and an individual who got into the defendant’s car were involved in attempt to break into cars in a parking lot which had a history of break-ins. Smith v. State, 245 Ga.App. 613, 538 S.E.2d 517 (August 21, 2000). Habitual violator conviction reversed; trial court erred by denying motion to suppress, as officer had no articulable suspicion for stop. Officer was patrolling apartment complex at night in area which had recently experienced “numerous burglaries and entering automobiles.” Officer saw defendant’s vehicle pulled over to the right in apartment complex parking lot, but not in a parking place. As officer approached, without blue lights activated, defendant made a “quick exit,” but “did not violate any traffic laws,” and officer didn’t claim that defendant left after seeing him. Officer pulled defendant over after he left the complex. Held, “[t]he simple fact that Smith was parked in an apartment parking lot late at night and then left the complex in the manner in which he did is clearly not sufficient to create a ‘particularized and objective’ basis for suspecting involvement in criminal activity.” Smith’s departure didn’t constitute “headlong flight,” given that there was no evidence that he noticed the officer’s car and didn’t even exceed the “10 or 15 mph” speed limit in the parking lot or violate any traffic laws. “[I]t is not illegal, nor even particularly suspicious, for a vehicle to be stopped briefly in the parking lot of a large apartment complex around midnight. Such conduct is at least as consistent with what was in fact transpiring—i.e., Smith dropping off his girlfriend—as with anything sinister.” Tomlin v. State, 242 Ga.App. 405, 530 S.E.2d 27 (February 16, 2000). Conviction for possession of marijuana affirmed; trial court properly denied motion to suppress evidence. Contrary to defendant’s argument, officers had articulable suspicion to stop his truck. “Narcotics Special Agent Holmes was driving behind a truck driven by Scott Tomlin when she saw a passenger in the truck smoking and then blowing smoke that smelled like marijuana out the truck window. … [W]hen Agent Holmes smelled marijuana coming from the truck, she had a reasonable suspicion that the vehicle contained marijuana.”