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encounter was a second-tier stop, not a first-tier encounter, “even if Satterfield stopped at the same time the officer pulled behind him.” “The patrol officer activated his blue lights when he pulled behind Satterfield and asked both occupants to step out of the car. The officer also testified that the occupants were not free to leave. We have previously found that similar conduct elevates a police-citizen encounter to the second-tier. O'Neal [ v. State, 273 Ga.App. 688, 690 (616 S.E.2d 479) (2005)] (police officer pulled next to parked van and activated blue lights); McKinley v. State, 213 Ga.App. 738, 739 (445 S.E.2d 828) (1994) (police officer pulled behind parked car, activated blue lights, and told driver to step back in his car). Compare McClain [ v. State, 226 Ga.App. 714, 716 (487 S.E.2d 471) (1997)] (finding first-tier encounter when police officer did not activate blue lights before approaching stopped vehicle and asking driver for identification).” Hinton v. State, 289 Ga.App. 309, 656 S.E.2d 918 (January 25, 2008). “‘Once a motor vehicle has been lawfully detained for a traffic violation, the police officers may order the driver to get out of the vehicle without violating the Fourth Amendment’s proscription of unreasonable searches and seizures.’ Salmeron v. State, 280 Ga. 735, 736(1) (632 S.E.2d 645) (2006) (citation and punctuation omitted).” Accord, Eaton v. State , 294 Ga.App. 124, 668 S.E.2d 770 (October 20, 2008) (“because concern for officer safety is still present at routine traffic stops, officers involved in any traffic stop may order the driver and any passengers out of the vehicle,” citing Knowles v. Iowa, 525 U.S. 113, 117 (119 S.Ct. 484, 142 L.Ed.2d 492) (1998), and Brendlin (June 18, 2007), below. Smith v State, 288 Ga.App. 87, 653 S.E.2d 510 (October 26, 2007). Trial court erred in denying defendant’s motion to suppress; stop was not supported by articulable suspicion of wrongdoing. “Here, the undisputed evidence shows that Smith’s movement was physically restrained when the police officer forcibly opened her car door. Faced with this situation, a reasonable person would be compelled to conclude that he or she was not free to drive away and to leave. Smith’s encounter with the police amounted to a detention, which in order to be lawful, must be supported by reasonable suspicion.” State v. Lanes, 287 Ga.App. 311, 651 S.E.2d 456 (August 21, 2007). Grant of defendant’s motion to suppress affirmed; based on facts as found by trial court, “the officer lacked a reasonable, articulable suspicion to ask Lanes to get out of his car,” thus turning first tier encounter into second-tier stop. Officer “observed a car parked in a closed gas station at 2:45 a.m. She approached the car and observed the driver, later identified as Lanes, ‘slumped down’ or ‘leaning forward’ and looking at a contact lens case in his hand . The officer tapped on the window, and Lanes ‘slowly looked over at’ her; she tapped again and he rolled down the window. When she asked what he was doing, he told her that he had just come from a nightclub and was ‘having problems with his contacts and wanted to let his eyes rest .’ His speech was ‘very, very slow,’ and his eyes were red and watery. She did not, however, smell any odor of alcohol. She asked Lanes if he had been smoking marijuana, and he denied it, although he said he had had a couple of beers at the nightclub. The officer asked for Lanes’s driver’s license, which she checked and found no outstanding warrants. She then asked him to step out of the car.” Trial court “found that Lanes gave a ‘reasonable explanation’ for his red and watery eyes, noting explicitly, ‘I don’t find anything else .... there was nothing there that I could see that would justify her asking him to step out of the car and taking his license from him.’” Accord, Smith v State , 288 Ga.App. 87, 653 S.E.2d 510 (October 26, 2007) (“Smith’s movement was physically restrained when the police officer forcibly opened her car door. Faced with this situation, a reasonable person would be compelled to conclude that he or she was not free to drive away and to leave.”). Keller v. State, 286 Ga.App. 292, 648 S.E.2d 714 (June 28, 2007). “Keller asserts that, because Deputy Downey asked him to get out of the vehicle, did not return his driver’s license, and told him that he was not going to be permitted to drive in his condition, he was in custody when asked to perform field sobriety tests. But these circumstances are more consistent with an ongoing investigation than an arrest, such that ‘a reasonable person could conclude that his freedom of action was only temporarily curtailed and that a final determination of his status was simply delayed.’ (Punctuation omitted.) Abrahamson v. State, 276 Ga.App. 584, 586 (623 S.E.2d 764) (2005).” Brendlin v. California, 551 U.S. 249, 127 S.Ct. 2400, 168 L.Ed.2d 132 (June 18, 2007). Defendant was a passenger in a car that was pulled over by police officer without articulable suspicion of any offense. Defendant was subsequently arrested on an outstanding warrant; illegal drugs were found in his possession in a search incident to arrest. Held, the passenger as well as the driver is seized by a stop of a vehicle. “When a police officer makes a traffic stop, the driver of the car is seized within the meaning of the Fourth Amendment. The question in this case is whether the same is true of a passenger. We hold that a passenger is seized as well and so may challenge the constitutionality of the stop .” Trial court thus erred when it found that “Brendlin was not seized until [Officer] Brokenbrough ordered him out of the car and formally arrested him.” Supreme Court holds that “ Brendlin was seized from the moment [driver’s] car came to a