☢ test - Í

entirely reasonable for the School District to enact this particular drug testing policy. … Respondents are correct that safety factors into the special needs analysis, but the safety interest furthered by drug testing is undoubtedly substantial for all children, athletes and nonathletes alike. We know all too well that drug use carries a variety of health risks for children, including death from overdose. … [R]easonableness under the Fourth Amendment does not require employing the least intrusive means.” Patman v. State, 244 Ga.App. 833, 537 S.E.2d 118 (July 7, 2000). Conviction for possession of marijuana with intent to distribute affirmed; officer had probable cause to search student for marijuana based on totality of circumstances. 1. Search would not have required probable cause if conducted by school official. “Although students are not stripped of their constitutional rights upon entering school, a student does not enjoy the same degree of privacy while on school property that he would enjoy elsewhere. See New Jersey v. T.L.O., 469 U.S. 325, 338–340, 105 S.Ct. 733, 83 L.Ed.2d 720 (1985). A student's interest in privacy must be balanced against ‘the substantial interest of teachers and administrators in maintaining discipline in the classroom and on school grounds.’ Id. at 339, 105 S.Ct. 733. Such discipline is necessary to provide students with a safe and secure school environment. See State v. Young, 234 Ga. 488, 496(2), 216 S.E.2d 586 (1975). Accordingly, the Fourth Amendment permits school officials to search students based upon circumstances which do not rise to the level of probable cause. T.L.O., supra at 341–342, 105 S.Ct. 733. The legality of a search of a student depends simply on the reasonableness, under all the circumstances, of the search. Id. In Georgia, school officials may search ‘subject only to the most minimal restraints necessary to insure that students are not whimsically stripped of personal privacy and subjected to petty tyranny.’ Young, supra at 497, 216 S.E.2d 586.” 2. Officer here had probable cause. “[Officer] Pope smelled marijuana on Patman , which gave rise to reasonable suspicion that he had recently smoked marijuana. See Cotton [ v. State, 237 Ga.App. 18, 513 S.E.2d 763 (1999)] Pope then patted Patman and felt what he believed to be packages of marijuana in Patman's pocket. When he asked Patman what was in the pocket, Patman's request to ‘let [him] slide’ suggested that he had something incriminating in his pocket. Taken together, the circumstances establish probable cause to search Patman, and the trial court did not err in denying his motion to suppress. See Williams [ v. State, 187 Ga.App. 409, 412(2), 370 S.E.2d 497 (1988)].” Disapproved “[t]o the extent that [it] 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). 32. TERRY PAT-DOWNS/FRISKS/SEARCHES May v. State, 334 Ga.App. 807, 780 S.E.2d 455 (November 20, 2015). Conviction for possession of methamphetamine affirmed; trial court properly denied motion to suppress. Called to residence on report of domestic disturbance , officers found May on the front porch; he told them his girlfriend had left. May allowed officer into home to verify her absence; there, officer saw a glass pipe typically used to smoke meth. Officer then decided to pat-down May for officer safety and “testified that during the pat-down, he felt a ‘little small bulge in [May’s] front, right pocket.’ He further testified, ‘I could tell as I manipulated it with my open hand that it was ... some sort of baggie and it had some sort of hard substance in it, crystal substance. In my training and past experience, I knew that was probably going to be contraband, that it was going to be methamphetamine.’ The State then asked, ‘So as soon as you began the pat-down, you immediately realized that it was some type of drug or baggie?’ The sergeant responded, ‘Controlled substance, yes, sir.’” Officer then removed the baggie from defendant’s pocket. Held, officer was entitled to remove the baggie based on plain-feel doctrine. “Although it is true that the sergeant used the word “manipulate” at one point in his testimony, we do not believe that his use of that word negates his other testimony that he immediately identified the object as contraband. Moreover, during cross-examination, the sergeant explained that he might have used the word ‘manipulate’ incorrectly and stood up and showed the trial court how he performed the pat-down. … [T]he trial court was able to view and assess how the sergeant demonstrated the pat-down. Since the trial judge had the benefit of observing this demonstration, and we do not, we must defer to the judge’s implicit finding that the sergeant’s demonstration provided credible support for his earlier testimony that he immediately identified the object as contraband.” Barnes, joined by Phipps, dissents, based on the word “manipulate,” citing Minnesota v. Dickerson, 508 U.S. 366, 378(III), 113 S.Ct. 2130, 124 L.Ed.2d 334 (1993) (“the police officer ‘overstepped the bounds of the “strictly circumscribed” search for weapons allowed under Terry ’ v. Ohio, 392 U.S. 1, 26, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968), when ‘the officer determined that the lump [of cocaine] was contraband only after squeezing, sliding and otherwise manipulating the contents of the defendant’s pocket—a pocket which the officer already knew contained no weapon.’ (Citation and punctuation omitted.)).” State v. Snead, 326 Ga.App. 345, 756 S.E.2d 581 (March 19, 2014). In drug and firearm prosecution, trial court erred in granting motion to suppress. On a suspicious-vehicle call, officers encountered Snead in his truck. He appeared to be impaired, and had a handgun, which he picked up but dropped on command. “Officer Hensley removed Snead from the