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demeanor would support a reasonable belief or suspicion that he was armed and dangerous, the State cannot justify the search under OCGA § 17-5-28(1).” Distinguishing Willis v. State , 122 Ga.App. 455, 459, 177 S.E.2d 487 (1970), where “the defendant was found in the same room with the persons named in the warrant in a position where drugs could have been passed easily from person to person. The Willis court recognized, however, that the search would not have been justified if the defendant had been in another part of the house.” 28. STANDING TO OBJECT TO SEARCH OR WARRANT Deleon-Alvarez v. State, 324 Ga.App. 694, 751 S.E.2d 497 (November 14, 2013). Defendants’ convictions for kidnapping for ransom affirmed. Defendant lacked standing to challenge wiretap where “he was not a subscriber of the phones tapped and that his voice was not heard during any conversation of the phones tapped,” citing Ellis v. State, 256 Ga. 751, 755(2) (353 S.E.2d 19) (1987) “(determining that defendant had no standing to challenge, under Georgia statutory law, the electronic surveillance of the telephone of his co-defendant, explaining that ‘[w]hen the voice of an individual is not heard and the tap is not on his premises, he has no standing’); Rogers v. State, 182 Ga.App. 599, 600(3) (356 S.E.2d 546) (1987) (concluding that trial court correctly denied appellant's motion to suppress the results of electronic surveillance by means of a wiretap on the telephone of a co-defendant, explaining that “[s]ince the wiretap was on [co- defendant's] telephone, appellant had no standing to object to an alleged violation of [co-defendant's] Fourth Amendment rights” and that ‘[s]ince none of appellant's Fourth Amendment rights were violated by the wiretap of [his co-defendant's] telephone, appellant was not an aggrieved person,’ was not entitled to the protection of the exclusionary rule, and thus had no standing to object to the wiretap of co-defendant's telephone).” Wilder v. State, 290 Ga. 13, 717 S.E.2d 457 (November 7, 2011). Reversing 304 Ga.App. 891, 698 S.E.2d 374 (2010); in defendant’s prosecution for child molestation and related offenses, trial court erred by holding that State’s seizure of defendant’s briefcase was valid under the independent source doctrine. Officer received information from victim and another woman that defendant had a briefcase full of photographic evidence of sex with victim, and that the briefcase was in possession of his friend, Malin. Officer contacted Malin and asked her to bring him the briefcase. Malin complied, and officer then obtained a search warrant to look inside. Trial court denied defendant’s motion to suppress the evidence found inside, holding that the seizure of the briefcase was unlawful, but “that the evidence was admissible under the independent source doctrine, which authorizes admission of evidence initially discovered through improper means if it was ultimately ‘obtained ... by a means untainted by and unrelated to the initial illegality.’ (Footnote omitted.) State v. Lejeune, 277 Ga. 749, 754(3)(A), 594 S.E.2d 637 (2004). See also Teal v. State, 282 Ga. 319(2), 647 S.E.2d 15 (2007).” Held, defendant had standing to challenge search and seizure of his briefcase. “Though lacking standing to challenge a search of Malin's premises, see, e.g., Brown v. State, 240 Ga.App. 321, 322, n. 2 (1), 523 S.E.2d 333 (1999) (search of premises owned by third party does not implicate defendant's Fourth Amendment rights), appellant does have standing to contest the seizure of his own personal property from the premises of another. Mooney v. State, [ v. State, 243 Ga. 373, 374–375, 254 S.E.2d 337 (1979)]. Compare English v. State, 288 Ga.App. 436(3), 654 S.E.2d 150 (2007) (no standing to challenge search of third party's premises and seizure of stolen vehicle stored there by defendant).” Anderson v. State, 292 Ga.App. 826, 666 S.E.2d 70 (June 27, 2008). Defendant lacked standing to object to search of safe where he disclaimed all knowledge or ownership of it. Brendlin v. California, 551 U.S. 249, 127 S.Ct. 2400, 168 L.Ed.2d 132 (June 18, 2007). Defendant was a passenger in a car that was pulled over by police officer without articulable suspicion of any offense. Defendant was subsequently arrested on an outstanding warrant; illegal drugs were found in his possession in a search incident to arrest. Held, the passenger as well as the driver is seized by a stop of a vehicle. “When a police officer makes a traffic stop, the driver of the car is seized within the meaning of the Fourth Amendment. The question in this case is whether the same is true of a passenger. We hold that a passenger is seized as well and so may challenge the constitutionality of the stop .” Trial court thus erred when it found that “Brendlin was not seized until [Officer] Brokenbrough ordered him out of the car and formally arrested him.” Supreme Court holds that “ Brendlin was seized from the moment [driver’s] car came to a halt on the side of the road. ” “When the actions of the police do not show an unambiguous intent to restrain or when an individual’s submission to a show of governmental authority takes the form of passive acquiescence, there needs to be some test for telling when a seizure occurs in response to authority, and when it does not. The test was devised by Justice Stewart in United States v. Mendenhall, 446 U.S. 544, 100 S.Ct. 1870, 64 L.Ed.2d 497 (1980), who wrote that a seizure occurs if ‘in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave,’ id ., at 554, 100 S.Ct. 1870 (principal opinion).” California Supreme Court found no seizure of a passenger, as an officer’s blue lights are generally directed at the driver, not the passenger, and a reasonable passenger would not believe he was being detained. U.S. Supreme Court disagrees: “A traffic stop necessarily curtails the travel a