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only if our Fourth Amendment jurisprudence ceases to treat secrecy as a prerequisite for privacy. I would not assume that all information voluntarily disclosed to some member of the public for a limited purpose is, for that reason alone, disentitled to Fourth Amendment protection.” Accord, Hamlett v. State , 323 Ga.App. 221, 746 S.E.2d 843 (July 16, 2013). W. SECOND-TIER ENCOUNTERS See also SEARCH AND SEIZURE – ARTICULABLE SUSPICION, above Seminal case: Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968). State v. Quarterman, 333 Ga.App. 803, 777 S.E.2d 485 (September 15, 2015). Physical precedent only. In prosecution for attempted murder and related offenses, trial court erred by granting motion to suppress; officer grab of car passenger, who was fleeing traffic stop after car chase, was second-tier encounter, not arrest. “Here, the officer’s act of grabbing Quarterman’s arm was a second-tier encounter, an attempted brief detention to investigate the suspicion of illegal activity,” citing McClary v. State, 292 Ga.App. 184, 187, 663 S.E.2d 809 (2008). “When Quarterman violently fought the officer during the attempted detention, he escalated the encounter to a third-tier encounter and gave the officer probable cause to arrest him for obstruction.” State v. Allen, 330 Ga.App. 752, 769 S.E.2d 165 (February 23, 2015). In prosecution for methamphetamine possession, trial court properly granted motion to suppress; officer lacked articulable suspicion to detain defendant. Officer ran tag of “suspicious” looking truck in parking lot and learned that its male owner, Couch, was wanted for a parole violation. “The deputy then turned his vehicle around, at which point he saw the truck now parked and a male and a female, who appeared to have just exited the vehicle, walking toward a Mexican restaurant in the shopping center. Believing the male to be Couch, the deputy used his patrol vehicle's PA system to request that both individuals stop. The couple, however, ignored this request and continued into the restaurant.” The officer found the female sitting alone in the restaurant; an employee told the officer that the male had exited the rear of the building. “[A]fter checking the bathroom and determining that Couch was not there, the deputy ordered Allen to step outside for further questioning, and she complied. By this time, a second law-enforcement officer arrived on the scene, and during the ensuing questioning, Allen acknowledged that Couch had mentioned that there was a warrant out for his arrest. The second officer then told Allen to call some of Couch's friends to inquire as to his whereabouts and ultimately asked Allen if he could search her purse. Allen consented, and during the search, the officer found a clear wrapper containing methamphetamine.” Held, the officers detained Allen, and had no articulable suspicion justifying the stop. 1. The encounter was a second-tier stop. “[T]he deputy who observed Allen and Couch walking toward the restaurant first requested that they stop, then approached Allen as she sat in a booth and, shortly thereafter, directed her to accompany him outside. Given these circumstances, no reasonable person in Allen's position would have felt free to end the encounter, and, in fact, the second officer to arrive on the scene explicitly testified at the hearing that Allen was not free to leave.” 2. “[A]lthough the deputy certainly possessed a reasonable, articulable suspicion to detain Couch, he had no basis whatsoever for believing that Allen was either committing, or was about to commit, a crime.[fn] Indeed, at the motion-to-suppress hearing, the deputy admitted that when he first approached Allen, as she sat in the restaurant booth, he had no suspicion that she had committed, or was about to commit, a crime. And while the deputy added that he believed Allen was untruthful when she told him that she was unsure as to where Couch had gone, the trial court, in granting Allen's motion to suppress, obviously found that her response did not provide an objective basis for a reasonable suspicion that she was obstructing the deputy in the lawful discharge of his official duties.” Wingate v. State, 296 Ga. 21, 764 S.E.2d 833 (October 20, 2014). Murder and armed robbery convictions affirmed; trial court erred, but harmless, in denying motion to suppress. Defendant, a high school student, was handcuffed by a school resource officer (SRO) and left alone and unattended in the SRO’s school office while awaiting officers investigating the murder of defendant’s uncle. When the SRO returned to the office, “he found a bag of marijuana on the floor near the stool on which Appellant was sitting that had not been there before. [SRO] Deputy Wortham then arrested Appellant for possession of marijuana, searched him incident to the arrest, and found $1,817 in his pocket, consisting of 18 $100 bills and a few smaller bills.” The money was admitted into evidence in defendant’s subsequent murder trial for the murder and robbery of his uncle. Held, trial court erred by finding that the search of defendant’s person was lawful “because Appellant was not detained when he abandoned the marijuana that was the basis for his arrest and the search of his pocket.[fn] The court concluded that Appellant had not been seized when Deputy Wortham left him handcuffed in the SRO office because he had gone to the office voluntarily and the officer told Appellant that he was not under arrest and left the office door open. This conclusion was erroneous, because the trial court failed to appreciate how Appellant's freedom to leave the office was hampered by the handcuffs that the officer had put on him. … [E]ven