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down a paper bag containing marijuana and cocaine. Defendant moves to suppress the drugs 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 (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. 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.” Lloyd v. State, 242 Ga.App. 503, 530 S.E.2d 228 (February 23, 2000). Conviction for cocaine possession affirmed; trial court properly denied motion to suppress, as officer had articulable suspicion for stop. “A police officer may conduct a brief investigative stop of a vehicle if he has specific and articulable facts which give rise to a reasonable suspicion of criminal activity. [Cit.] In the instant case, Officer Mitchell had such specific and articulable facts when he saw that Lloyd matched the description of the person who had fled from the prior traffic stop [about an hour earlier], that Lloyd was in the area where that suspect had fled, see Shapiro v. State, 233 Ga.App. 620, 621(2), 504 S.E.2d 719 (1998), and that Lloyd tried to flee when the officer asked him to stop. See Lee v. State, 270 Ga. 798, 803(7), 514 S.E.2d 1 (1999) (flight is a circumstance that may give rise to an articulable suspicion of criminal activity so as to authorize a brief investigative stop). All of these facts gave Officer Mitchell a reasonable suspicion of criminal activity that justified his stop of Lloyd's vehicle. Brown v. State, 239 Ga.App. 674, 522 S.E.2d 41 (August 18, 1999). No ineffective assistance of counsel for failure to file motion to suppress; regardless of whether officers had articulable suspicion for traffic stop, drugs thrown from speeding car during police chase were not improperly seized. “‘ Where a defendant is in a state of flight when he discards or abandons property which he now seeks to suppress, his being pursued does not result in the “seizure” of property he abandoned.’ Walker v. State, 228 Ga.App. 509, 510(1), 493 S.E.2d 193 (1997). Because Brown was in a state of flight when he discarded the cocaine in question, and had not submitted to any show of authority by the police, the cocaine was not discovered as a result of an illegal search or seizure, regardless of whether the police had probable cause to stop Brown's vehicle. Accordingly, ‘a motion to suppress would have been meritless, and [Brown's] ... counsel was therefore not ineffective for failing to [pursue] such motion.’ Crews v. State, 226 Ga.App. 232, 233(1), 486 S.E.2d 61 (1997).” Ransom v. State, 239 Ga.App. 501, 521 S.E.2d 430 (July 30, 1999). Defendant’s flight from first-tier encounter, coupled with other suspicious circumstances, justified officer’s stop and temporary detention: “ Ransom's flight, coupled with his earlier, suspicious behavior in hiding behind a tree at the approach of law enforcement and his presence in a known drug sale location for no apparent purpose, provided Officer Davis with at least a reasonable suspicion of Ransom's criminal activity to warrant further investigation. State v. Grimes, 195 Ga.App. 773, 774(1), 395 S.E.2d 42 (1990). See also Tuggle v. State, 236 Ga.App. 847, 512 S.E.2d 650 (1999); Castillo v. State, 232 Ga.App. 354, 356-357, 502 S.E.2d 261 (1998); Walker v. State, 228 Ga.App. 509, 511(1), 493 S.E.2d 193 (1997); State v. Webb, 193 Ga.App. 2, 4(1), 386 S.E.2d 891 (1989); Scott v. State, 193 Ga.App. 74, 387 S.E.2d 31 (1989); State v. Billoups, 191 Ga.App. 834, 383 S.E.2d 198 (1989). That such further investigation necessarily entailed a foot chase was due only to Ransom's refusal to halt at Officer Davis' authorized request.” Accord, Quarterman (September 15, 2015), above (car passenger’s flight after car chase provided articulable suspicion for his temporary detention).