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noncriminal traffic offense. Id.” “[U]pon a showing of probable cause to arrest for the offenses of DUI (OCGA § 40-6- 391) or reckless driving (OCGA § 40-6-390), either of these offenses is a sufficiently serious criminal activity to justify an officer's warrantless, nonconsensual entry into a suspect's home to arrest the suspect – if exigent circumstances exist to justify the entry. ” 2. No exigent circumstance here. “The reckless operation of the car and the consequent threat to public safety had ended. With two officers present, one could have gone to obtain an arrest warrant, while the other stayed to ensure that Threatt did not leave. As to the reckless driving, there was no fear of destruction of evidence if the arrest was delayed in order to obtain a warrant. Moreover, there was no evidence that Threatt attempted to evade or delay any investigation or arrest by refusing to come out of his apartment or by refusing entry to the officers. Yet the officers did not ask Threatt to come out of his apartment until after an officer had entered the residence and questioned him, nor did the officers seek permission to enter. … It follows that the questioning of Threatt inside his apartment violated his Fourth Amendment right to be secure in his home from unreasonable searches or seizures. The trial court should have granted Threatt's motion to suppress to the extent it sought to exclude all evidence obtained during the questioning inside the apartment.” State v. Sims, 240 Ga.App. 391, 523 S.E.2d 619 (October 18, 1999). Trial court’s suppression of evidence obtained through warrantless entry into defendant’s home affirmed; doors left ajar at residence, absent other circumstances, don’t give officers exigent circumstances to enter. Officers went to defendant’s home investigating damage to public school grounds by a four-wheeler. They saw a four-wheeler in defendant’s driveway about a mile away from the school. Officers knocked on each door of the house, got no answer, but heard sounds like a radio inside the house and saw cars in the open garage. They found an open garage door leading into the basement, entered it to insure there was no criminal activity, then climbed a staircase to the first floor of the home, which they entered through a closed but unlocked door. Even where probable cause exists, the Fourth Amendment, absent consent or a showing of exigent circumstances, prohibits warrantless intrusion of a person’s home. Here, there were no exigent circumstances: “The police were investigating an already completed crime. They were not responding to a call or complaint, but simply looking for any ‘four-wheeler’ without any more particular description. They walked around Sims's house and found nothing suspicious even after entering the basement, walking upstairs, and entering the living area through a closed door.” Distinguishing Gilreath v. State, 247 Ga. 814, 279 S.E.2d 650 (1981) (entry justified by reported threats of violence, doors ajar, and strong odor or gasoline; body of murder victim was visible inside when police entered screened porch). State’s claim here that entry was pursuant to sheriff’s policy of always securing residences with open doors doesn’t make it constitutional. “A garage or basement door left open to admit light and air does not constitute a blanket invitation to the police to enter and certainly not to continue their entry through closed doors into the residence itself after finding nothing amiss.” Notes different rule may apply to commercial property, citing Banks v. State, 229 Ga.App. 414, 493 S.E.2d 923 (1997), overruled on other grounds, Calbreath v. State, 235 Ga.App. 638, 640, n. 3, 510 S.E.2d 145 (1998). Brown v. State, 240 Ga.App. 321, 523 S.E.2d 333 (September 16, 1999). Defendant’s conviction for obstruction affirmed; although an arrest warrant for Brown didn’t authorize officers to make non-consensual entry into someone else’s home to arrest Brown, that violation of the homeowner’s rights didn’t make the arrest of Brown unlawful. Thus, “we conclude the officers were engaged in the lawful discharge of their duties with regard to Brown,” and evidence supported the conviction. “It is now well established that even when armed with an arrest warrant, police must have either a search warrant, exigent circumstances or consent to lawfully enter a third person's home to arrest someone who does not reside there. Steagald v. United States, 451 U.S. 204, 212-215, 101 S.Ct. 1642, 68 L.Ed.2d 38 (1981); King v. State, 217 Ga.App. 889, 891, 459 S.E.2d 605 (1995).” Steward v. State, 237 Ga.App. 672, 516 S.E.2d 534 (April 14, 1999). Police properly searched visitor to search warrant premises, not based on warrant, but on additional probable cause. “An ‘other party’ entering the premises during the search may not be searched when that person had no opportunity to conceal any of the items described in the search warrant. Wallace v. State, [131 Ga.App. 204, 205(1), 205 S.E.2d 523 (1974)]. Therefore, unless the police had independent probable cause justifying the warrantless search of Steward’s person and personal belongings, the cocaine seized should have been suppressed. See id.; see also State v. Anderson, 195 Ga.App. 793, 395 S.E.2d 50 (1990); Logan v. State, 135 Ga.App. 879, 885(3), 219 S.E.2d 615 (1975). Under the peculiar circumstances of this case, we believe the officers had probable cause to search Steward. As we have explained, OCGA § 17-5-28 does not limit an officer’s right to search persons for whom probable cause for a warrantless search exists . Ledford v. State, [233 Ga.App. 445, 46(1), 504 S.E.2d 512 (1998)]. A finding of probable cause is not limited or defined ‘“in relation to any one particular element, but may exist because of the totality of the circumstances surrounding a transaction.”’ Moody v. State, 232 Ga.App. 499, 504-505(4)(b), 502 S.E.2d 323 (1998). In this case, the officers knew that drug dealing from the apartment had been heavy that day. They knew the apartment residents were being supplied by a Miami connection who had gold teeth. They

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