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Williams v. State, 318 Ga.App. 715, 734 S.E.2d 535 (November 20, 2012). Conviction for trafficking in cocaine reversed; trial court erred in denying motion to suppress based on Terry pat-down. Officer had no right to demand that defendant remove item from his pocket when “the undisputed evidence shows that the officer could not readily identify the bulge in Williams's pocket as either a weapon or contraband. The officer admitted unequivocally that he had ‘no idea’ what the bulge was until he opened the paper bag and discovered the cocaine. He further stated that the object did not feel like a weapon to him, and during his testimony he never indicated that, upon feeling the object, he suspected it was contraband. Additionally, the officer testified unequivocally that at the time he conducted the pat down, Williams presented no danger to him, and he offered no testimony indicating that he had a reasonable basis for believing that Williams might be armed with any kind of weapon.” State v. Cleveland, 319 Ga.App. 225, 738 S.E.2d 273 (October 5, 2012). In prosecution for cocaine possession, trial court properly granted motion to suppress. “[Officer] Clark's search went beyond a mere Terry -authorized pat-down when he directed Cleveland to remove his shoes. Such an intrusion beneath the surface of a suspect's clothing requires further justification: ‘…Under Terry, an officer is authorized to pat down a suspect's outer clothing. He may intrude beneath the surface in only two instances: (1) if he comes upon something that feels like a weapon, or (2) if he feels an object whose contour or mass makes its identity as contraband immediately apparent, i.e., the “plain feel” doctrine.’ (Citation omitted.) Johnson v. State, 297 Ga.App. 847, 848 (678 S.E.2d 539) (2009). Clark never testified that he felt any object in or around Cleveland's shoes or that the shoes were of a material or thickness that would have prevented him from detecting a weapon during a pat-down search; thus, the State provided no evidence to justify requiring Cleveland to remove his shoes.” Cleveland also exhibited no threatening conduct justifying the intrusion. Mwangi v. State, 316 Ga.App. 52, 728 S.E.2d 729 (May 23, 2012). Convictions for theft by taking and related offenses affirmed. Trial court properly denied motion to suppress, as officer had basis for pat-down. “[Officer] Masselter had a particularized and objective basis for suspecting that Mwangi was involved in criminal activity, because Masselter knew that within the preceding hour or so, a woman had called 911 after the motion-sensor lights on her home came on and after a strange truck had blocked her driveway. He knew that the truck belonged to a business in another area; that an unidentified male had walked away from the truck; and that in this neighborhood there recently had been a number of ‘entering auto’ incidents involving items stolen from unlocked cars. Based on these facts, Masselter believed that the driver of the truck was probably on foot in the neighborhood. When the officers encountered Mwangi, he was alone, late at night, only about six blocks from the home where the 911 call originated. Masselter testified that Mwangi was ‘nervous’ and ‘shaking’ and ‘looked very shocked to see us.’ … As explained in Terry v. Ohio, an ‘officer need not be absolutely certain that the individual is armed; the issue is whether a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger.’ (Citations omitted.) Terry, [392 U.S. 1, 27(III) (88 S.Ct. 1868, 20 L.Ed.2d 889) (1968)].” Jones v. State, 314 Ga.App. 247, 723 S.E.2d 697 (February 21, 2012). Conviction for possession of methamphetamine affirmed; officer’s safety concerns justified taking defendant down and patting him down for weapons (resulting in discovery of drugs). Circumstances included “that the officers were searching the house to execute an arrest warrant for a resident thereof, suspicion of drug activity at the house had been reported by neighbors, and Jones, who was sitting up in bed, failed to comply with [Officer] Stamey's repeated commands that Jones display his hands, which were obscured under the covers. See O'Quinn v. State, 303 Ga.App. 657, 659 (695 S.E.2d 60) (2010); Vaughn v. State, 247 Ga.App. 368, 369–370(1) (543 S.E.2d 429) (2000) (physical precedent only); Hodges [ v. State, 217 Ga.App. 806, 808(2) (460 S.E.2d 89) (1995)]. Compare State v. Varner, 239 Ga.App. 347 (521 S.E.2d 247) (1999) (affirming the trial court's finding that officer lacked probable cause to effect a patdown of a handcuffed individual on the basis of officer safety).” Lewis v. State, 307 Ga.App. 593, 705 S.E.2d 693 (January 21, 2011). Loitering and prowling, and weapons, convictions affirmed; trial court properly denied motion to suppress weapon found on defendant’s person during pat-down. “The initial pat-down of Lewis was supported by the following combined, particularized facts observed by the officers: the presence of Lewis late at night in a high-crime area known for armed robberies; his proximity to a closed convenience store that had been robbed on numerous occasions during closing; Lewis's observation of the store manager in the process of closing the store while standing in an unlit parking lot; his extreme nervousness; his wearing of baggy clothing in which a weapon could be easily concealed; the inadequacy of his explanation to the officers for his presence outside the store; and his initial fleeing from the officers when they pulled into the parking lot. These actions of Lewis were consistent with the officers' hypothesis that Lewis was contemplating a robbery of the store manager, ‘which, it is