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see Reynolds v. State, 280 Ga.App. 712, 634 S.E.2d 842 (July 26, 2006) (even flight from improper second-tier stop gives rise to probable cause to arrest) which they did shortly thereafter, but also to search the Mitsubishi, identified by this time as Fleming’s, which he had left at the scene before getting into the Yukon. See Scott v. State, 277 Ga.App. 126, 128-129(2) (625 S.E.2d 526) (2006) (upholding warrantless search of a car left open and running in a parking lot when the defendant and others fled from a second car); Jones v. State, 195 Ga.App. 868, 869(2) (395 S.E.2d 69) (1990) (totality of circumstances, including information from concerned citizen, flight of the accused, and observations by police officers, can yield probable cause to justify search of vehicle); McKinney v. State, 184 Ga.App. 607, 609-610(2) (362 S.E.2d 65) (1987) (upholding warrantless search of a car when officers had probable cause to suspect it contained contraband even though the driver was arrested and handcuffed and the keys were taken from him before the car was searched). Where probable cause to search a car exists, an officer need not obtain a warrant before searching it for suspected contraband. Benton v. State, 240 Ga.App. 243 (522 S.E.2d 726) (1999). Because the police had authority under these circumstances to conduct a warrantless search of Fleming’s automobile, we conclude that the trial court did not err when it denied the motion to suppress.” Jackson v. State, 281 Ga.App. 83, 635 S.E.2d 372 (August 11, 2006). Cocaine trafficking and related convictions affirmed; no ineffective assistance from failing to pursue meritless motion to suppress. “As the police pulled up to 1981 Meadow Lane to execute the search warrant , they noticed the Ford vehicle parked on the property next to the target house. The house on that property looked to be abandoned, and the Ford’s engine was running, but nobody was inside the vehicle. When police executed the search warrant, they found Jackson in the bathroom with 90 grams of cocaine, more than $1,000 in cash and a Ford car key. Jackson told police he had just stopped by the house for a shower. Police determined that the key found in Jackson’s clothing fit the idling car, and a drug dog that was part of the warrant team conducted an open air sniff on the outside of the idling vehicle. The drug dog alerted to the presence of drugs. When police opened the vehicle they found Jackson’s identification and over one ounce of marijuana in the steering column. This was a proper warrantless search.” United States v. Williams, 185 Fed. Appx. 866 (11 th Cir., June 21, 2006). “[T]he officers’ warrantless search of Williams’s car, including the trunk, was valid, under the so-called ‘automobile exception’ to the Fourth Amendment’s warrant requirement. See Maryland v. Dyson, 527 U.S. 465, 466, 119 S.Ct. 2013, 2014, 144 L.Ed.2d 442 (1999). Under the automobile exception, warrantless searches of vehicles are permitted ‘“[i]f a car is readily mobile and probable cause exists to believe it contains contraband....”’ Id. at 467, 119 S.Ct. at 2014 (citation omitted) (emphasis added). Williams does not dispute that the car was readily mobile. [Footnote 3: It is well-established that a vehicle need only be ‘operational’ in order to satisfy this requirement. United States v. Watts, 329 F.3d 1282, 1286 (11th Cir., 2003); see also Dyson, 527 U.S. at 467, 119 S.Ct. at 2014 (no separate finding of any exigency is required to search readily mobile car if there is probable cause to believe the car contains contraband). ] ” Compare Lejeune (February 10, 2003), below. Bowden v. State, 279 Ga.App. 173, 630 S.E.2d 792 (May 3, 2006). Methamphetamine possession and trafficking convictions affirmed. Where circumstances authorized detention of driver and vehicle on articulable suspicion of involvement in a drug deal, “the bringing of the drug dog to the scene during that brief detention was proper. Gary v. State, 249 Ga.App. 879, 880-881(1) (549 S.E.2d 826) (2001). When the drug dog alerted to the vehicle as containing drugs, the subsequent warrantless search of the vehicle was justified. See Williams v. State, 273 Ga.App. 637, 639(1) (615 S.E.2d 789) (2005) (‘the “alert” of a trained narcotics dog, standing alone, [is] sufficient to provide probable cause for the search of a vehicle’). See generally Pennsylvania v. Labron, 518 U.S. 938, 940 (116 S.Ct. 2485, 135 L.Ed.2d 1031) (1996). (‘[i]f a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment ... permits police to search the vehicle without more’).” Megesi v. State, 277 Ga.App. 855, 627 S.E.2d 814 (February 15, 2006). Physical precedent only: “[W]hen an officer is informed during a traffic stop that a weapon, licensed or otherwise, is in the vehicle, the officer may secure the weapon for his protection. Regardless of whether this particular officer felt personally threatened, a reasonably prudent man in the officer’s position would be warranted in believing that, because of the weapon’s presence, his safety was in danger while he executed the roadside stop .” Note, “[t]his was not a search to determine whether a weapon was present; the officer knew that a weapon was present because Megesi told him so, and after Megesi got out of the vehicle, the officer could see the pistol, which he then secured for his personal safety. Moreover, we note that an officer securing a weapon during a traffic stop, under these circumstances, does not significantly lengthen the traffic stop or increase the degree of privacy intrusion.” Based on Maryland v. Wilson, 519 U.S. 408, 415 (117 S.Ct. 882, 137 L.Ed.2d 41) (1997) (“During a valid traffic stop, an officer may order both the driver and the passengers from the car.”);
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