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passenger has chosen just as much as it halts the driver, diverting both from the stream of traffic to the side of the road, and the police activity that normally amounts to intrusion on ‘privacy and personal security’ does not normally (and did not here) distinguish between passenger and driver. United States v. Martinez-Fuerte, 428 U.S. 543, 554, 96 S.Ct. 3074, 49 L.Ed.2d 1116 (1976). An officer who orders one particular car to pull over acts with an implicit claim of right based on fault of some sort, and a sensible person would not expect a police officer to allow people to come and go freely from the physical focal point of an investigation into faulty behavior or wrongdoing. If the likely wrongdoing is not the driving, the passenger will reasonably feel subject to suspicion owing to close association; but even when the wrongdoing is only bad driving, the passenger will expect to be subject to some scrutiny, and his attempt to leave the scene would be so obviously likely to prompt an objection from the officer that no passenger would feel free to leave in the first place.” Accord, State v. Menezes , 286 Ga.App. 280, 648 S.E.2d 741 (July 3, 2007) (passenger had standing to contest stop – and thus resultant search – of vehicle, citing Brendlin ); Cooper (February 27, 2003), below. Distinguished as to bus passesngers, Solano-Rodriguez v. State , 295 Ga.App. 896, 673 S.E.2d 351 (February 10, 2009) ( quoting Brendlin, “the relationship between driver and passenger is not the same in a common carrier as it is in a private vehicle, and the expectations of police officers and passengers differ accordingly.”). Stinski v. State, 281 Ga. 783, 642 S.E.2d 1 (February 2, 2007). “Although ‘the burden of proving the search and seizure were lawful shall be on the state,’ OCGA § 17-5-30(b), Davis v. State , 266 Ga. 169(1), 465 S.E.2d 438 (1996), the defendant bears the burden of proof where his or her standing to challenge the legality of a search or seizure is challenged by the State . Todd v. State , 275 Ga. 459(1), 620 S.E.2d 666 (2005); Atwater v. State , 233 Ga. 339(2), 503 S.E.2d 919 (1998). See OCGA § 24-4-1; see also 6 LaFave, Search and Seizure, § 11.2(b), pp.46-47 (4 th ed. 2004)). Defendant failed to carry this burden here, as the only evidence presented on defendant’s motion to suppress indicated that the bag in question was stolen by defendant, and he thus lacked standing to contest the search of it. Accord, Lowe v. State , 295 Ga. 623, 759 S.E.2d 841 (June 16, 2014). Feaster v. State, 283 Ga.App. 417, 641 S.E.2d 635 (February 2, 2007). Armed robber could not object to search of luggage he had just stolen. “Feaster had no standing to assert a Fourth Amendment challenge in this regard because he had no proprietary interest in the bags or legitimate expectation of privacy regarding the bags he took by gunpoint or their contents. [Cits.]” Accord, Stinski (February 5, 2007), above. Valle v. State, 282 Ga.App. 223, 638 S.E.2d 394 (November 2, 2006). Defendant lacked standing to challenge search of garbage bag he placed in someone else’s car trunk. “Valle chose to put the garbage bag in the trunk of a car that he did not own and over which he exercised no control. Furthermore, the container involved – a garbage bag, rather than a suitcase or a briefcase – ‘is not traditionally a receptacle for private items. ’ [ State v. Robinson, 278 Ga.App. 511, 512 (629 S.E.2d 509) (2006).] Under these circumstances, Valle has no reasonable expectation of privacy in the garbage bag he placed in the trunk. See Mecale v. State, 186 Ga.App. 276, 277-278 (367 S.E.2d 52) (1988). It follows that the trial court did not err in finding Valle lacked standing to challenge the search.” Defendant was passenger in vehicle; police knew defendant placed garbage bag (which appeared to contain drugs) in trunk. Black v. State, 281 Ga.App. 40, 635 S.E.2d 568 (August 10, 2006). Officers illegally arrested defendants’ son, then brought him home to search his room by his consent. Defendants also consented to search of their bedroom, which revealed methamphetamines. Held, search of defendants’ bedroom was product of illegal arrest of defendants’ son; defendants have standing to challenge the legality of the search of their own bedroom, and thus the underlying arrest. State v. Robinson, 278 Ga.App. 511, 629 S.E.2d 509 (March 28, 2006). Trial court erred in granting motion to suppress; defendant had no standing to challenge search of hamburger bag. Officer approached defendant and two other men, standing in an apartment breezeway frequently used for drug sales. “When the … officer approached, he came upon three men and noticed the smell of burnt marijuana. He asked the men for identification and asked if he could talk to them and pat them down. They consented.” First man searched put a hamburger he was eating in a McDonald’s bag and put it on the ground. Defendant then “‘picked up the McDonald’s bag and crushed it to his chest.’ When the officer observed Robinson ‘move[ ] the bag to his back,’ he asked Robinson if he could look inside the bag, and Robinson handed it over. Inside the bag the officer found a partially eaten hamburger and small individual bags of marijuana.” Held, defendant had no standing to challenge the search of his friend’s hamburger bag. “Robinson appears to assert that his property or possessory interest in the McDonald’s bag was created when he grabbed the bag. He argues that because he ‘exercised dominion and control over the bag’ and did not deny his possessory interest in it, he had standing to challenge the search of the bag. We disagree. ‘The Fourth Amendment right against unreasonable search and seizure is a personal right, so a defendant may challenge the legality of a search only where his or her own rights were violated. The Fourth Amendment