☢ test - Í

was in Boldin’s residence.” Notes distinction between mere “odor of marijuana” and “odor of burning marijuana.” Although the odor of marijuana may not suffice by itself to provide probable cause for the search of a residence , State v. Charles, 264 Ga.App. 874, 876(2) (592 S.E.2d 518) (2003) (trial court’s order suppressing evidence affirmed where no evidence that ‘slight odor of marijuana’ was from current use inside motel room); Shivers v. State, 258 Ga.App. 253, 257 (573 S.E.2d 494) (2002) (denial of motion to suppress reversed; odor of burnt marijuana on defendant’s person, without more, failed to establish probable cause for search of his home), the odor of burning marijuana is one of the factors which, under the totality of the circumstances, will support a finding of probable cause. State v. Fossett, 253 Ga.App. 791, 793(1) (560 S.E.2d 351) (2002).” Evidence also supported finding of exigent circumstances. “‘A classic example of exigent circumstances is the likelihood that contraband is in danger of immediate destruction.’ (Footnote omitted.) Land v. State, 265 Ga.App. 859, 861(1) (595 S.E.2d 540) (2004) (warrantless entry justified by threat that evidence would be destroyed, where defendants inside residence knew officers were at door but refused to open). Accord, e.g., Simmons v. State, 278 Ga.App. 7, 8(1) (627 S.E.2d 928) (2006) (police standing at door saw defendant throw plastic bag containing cocaine into fire; warrantless entry justified to prevent destruction of evidence); Binkley, supra (warrantless entry justified where defendant could have destroyed evidence when he went back inside house); Taylor v. State, 254 Ga.App. 150, 151-152(1) (561 S.E.2d 833) (2002) (same); David, supra (officer’s warrantless entry justified by likelihood that contraband would be destroyed, where officer saw occupant attempt to conceal contraband). Because illegal drugs can easily and swiftly be destroyed, the exigent circumstance doctrine is especially necessary in narcotics cases. Alvarado v. State, 271 Ga.App. 714, 715-716(1) (610 S.E.2d 675) (2005) (exigent circumstances existed where man talking on cell phone in front of defendant’s residence could have been warning defendant to destroy contraband). In the case at bar, the trial court was authorized to find from the evidence that the officers had reasonable grounds to believe that, once inside the house and out of sight of the officers, Boldin would hide or destroy the contraband, based on Boldin’s flight into the house upon sight of the police officers, his slamming closed the door to the house, and the contraband he dropped that lay in plain sight in the garage. The trial court therefore did not err in denying Boldin’s motion to suppress.” Boldin, Shivers, Charles and Fossett disapproved “[t]o the extent that [they] could be interpreted as support for the premise that the odor of raw marijuana emanating from a particular location cannot be the sole basis for the issuance of a search warrant for that location,” State v. Kazmierczak , 331 Ga.App. 817, 771 S.E.2d 473 (March 30, 2015). Valle v. State, 282 Ga.App. 223, 638 S.E.2d 394 (November 2, 2006). Where defendant consented to search of his residence, evidence was admissible against him notwithstanding his girlfriend’s refusal to consent. Distinguishing Randolph (March 22, 2006), below. “‘The Fourth Amendment right against unreasonable search and seizure is a personal right and may not be asserted vicariously.’ Hall v. State, 258 Ga.App. 502, 504(1)(a) (574 S.E.2d 610) (2002). Thus, such right ‘may be enforced only at the instance of the person whose protection was infringed by the search and seizure.’ State v. Jackson, 243 Ga.App. 330 (533 S.E.2d 433) (2000). The Randolph case, upon which Valle relies, stands for the proposition that ‘a physically present co-occupant’s stated refusal to permit entry prevails, rendering the warrantless search unreasonable and invalid as to him. ’ (Emphasis supplied.) Georgia v. Randolph, 547 U.S. 103 (126 S.Ct. 1515, 164 L.Ed.2d 208) (2006). It does not vicariously impute [girlfriend’s] refusal to consent valid as to Valle.” Girlfriend was present here and refused consent to search; but State did not seek here to admit evidence against her, so her consent was irrelevant. Accord, Moorer v. State , 286 Ga.App. 395, 649 S.E.2d 537 (July 6, 2007). Black v. State, 281 Ga.App. 40, 635 S.E.2d 568 (August 10, 2006). Consent to search residence was invalid where obtained by illegal arrest of occupant. Brigham City v. Stuart, 547 U.S. 398, 126 S.Ct. 1943, 164 L.Ed.2d 650 (May 22, 2006). “In this case we consider whether police may enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury. We conclude that they may .” Test is not dependent on officers’ subjective intent to make arrests rather than to assist victims. “An action is ‘reasonable’ under the Fourth Amendment, regardless of the individual officer’s state of mind, ‘as long as the circumstances, viewed objectively, justify [the] action.’ Scott v. United States, 436 U.S. 128, 138, 98 S.Ct. 1717, 56 L.Ed.2d 168 (1978) (emphasis added). The officer’s subjective motivation is irrelevant. See Bond v. United States, 529 U.S. 334, 338, n. 2, 120 S.Ct. 1462, 146 L.Ed.2d 365 (2000) (‘The parties properly agree that the subjective intent of the law enforcement officer is irrelevant in determining whether that officer’s actions violate the Fourth Amendment ...; the issue is not his state of mind, but the objective effect of his actions’); Whren v. United States, 517 U.S. 806, 813, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996) (‘[W]e have been unwilling to entertain Fourth Amendment challenges based on the actual motivations of individual officers’); Graham v. Connor, 490 U.S. 386, 397, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989) (‘[O]ur prior cases make clear’ that ‘the subjective motivations of the individual officers ... ha[ve] no bearing on whether a particular