☢ test - Í

evidence of appellant's guilt, we find the error, if any, harmless beyond a reasonable doubt. See Hill, supra at 284(4)(b), 295 S.E.2d 518.” Accord, Sears v. State , 292 Ga. 64, 734 S.E.2d 345 (November 19, 2012). Mullinax v. State, 242 Ga.App. 561, 530 S.E.2d 255 (March 1, 2000). Theft by receiving conviction affirmed; trial court properly admitted evidence that defendant was unable to produce proof of ownership to officer at time of arrest. Contrary to defendant’s argument, such evidence was not improper comment on defendant’s silence under Mallory v. State, 261 Ga. 625, 629–630(5), 409 S.E.2d 839 (1991). “This court has not interpreted Mallory … to bar evidence otherwise admissible as part of the res gestae of the crime. Boykin v. State, 240 Ga.App. 402, 403–404(1), 523 S.E.2d 605 (1999). ‘As a general rule, all the circumstances connected with a defendant's arrest are admissible as a part of the res gestae.’ (Citation and punctuation omitted.) Anderson v. State, 236 Ga.App. 679, 682(4), 513 S.E.2d 235 (1999). When such evidence is relevant for the purpose of showing the circumstances of the arrest, it need not be excluded simply because it is prejudicial. Id. In this case, Mullinax was charged with receiving stolen property, and the fact that he did not have proof of ownership when arrested was very relevant to the issues at trial. This was not a matter of silence; a police officer conducting a traffic stop has a right to request and examine such documents as a driver's license, proof of insurance, and registration of the vehicle and may run a computer check of these documents. Sutton v. State, 223 Ga.App. 721, 723, 478 S.E.2d 910 (1996); accord Williams v. State, 233 Ga.App. 70, 71(1), 503 S.E.2d 324 (1998).” Johnson v. State, 241 Ga.App. 448, 526 S.E.2d 903 (December 14, 1999). Defendants’ convictions for attempted armed robbery affirmed; no mistrial required based on prosecutor’s improper question implicating defendant’s silence, given that the question was not answered. “‘“ Where an objected-to question is not answered by the witness there is no harmful error. (Cit.)” [Cit.],’ quoting Watkins v. State, 206 Ga.App. 701, 706(4), 426 S.E.2d 238 (1992).” Boykin v. State, 240 Ga.App. 402, 523 S.E.2d 605 (October 18, 1999). Defendant’s burglary conviction affirmed; no improper comment on defendant’s silence: “During cross-examination of [Officer] Ormond, defense counsel challenged the thoroughness of the officer's investigation. Counsel inquired whether Ormond had asked Boykin what happened. Ormond testified that he had asked this question but Boykin had not responded. On redirect examination, the prosecuting attorney asked Ormond if he had given Boykin an opportunity to explain why she was in the store, and he responded affirmatively.” Held, officer’s testimony was not barred by Mallory v. State , 261 Ga. 625, 409 S.E.2d 839 (1991): “Ormond's comments concerning Boykin's post-arrest silence were elicited, not by the prosecutor, but by defense counsel during his cross-examination of the officer. This testimony could have been introduced by the State, however, because Mallory does not apply to comments concerning a defendant's post-arrest silence , [fn: See Landers v. State, 270 Ga. 189, 190(2), 508 S.E.2d 637 (1998) (noting that it had been held in Mallory ‘that the state may not comment on either a defendant's silence prior to arrest or failure to come forward voluntarily, even when the defendant chooses to testify at trial’) . ] and it does not appear from the record that Boykin's silence was induced by Miranda warnings.” Underlying Mallory : Jenkins v. Anderson , 447 U.S. 231, 100 S.Ct. 2124, 65 L.Ed.2d 86 (1980), and Fletcher v. Weir, 455 U.S. 603, 102 S.Ct. 1309, 71 L.Ed.2d 490 (1982). “ Jenkins allows the State to comment at trial upon the fact that the defendant did not come forward voluntarily, if the defendant's pre-arrest silence has not been induced by government action (i.e., Miranda warnings) and the defendant has waived his privilege against self-incrimination by testifying at trial. Fletcher holds that, as a matter of federal due process, the State may permit cross-examination about a defendant's post- arrest silence so long as such silence is not induced by Miranda warnings.” Note, Mallory does not appear to be limited to pre-arrest silence (“We take this opportunity to hold that in criminal cases, a comment upon a defendant's silence or failure to come forward is far more prejudicial than probative. Accordingly, from the date of publication of this opinion, … such a comment will not be allowed even where the defendant has not received Miranda warnings and where he takes the stand in his own defense.”). Crowder v. State, 237 Ga.App. 312, 513 S.E.2d 752 (March 1, 1999). Mistrial was not required where officer, on cross-examination, twice mentioned defendant’s silence and request for counsel upon arrest. Distinguishing Hill v. Turpin , 135 F.3d 1411 (11 th Cir., 1998): “defense counsel may have invited the comments about which [he] complains by the direct questions he posed to [Agent] Lanier. More importantly, … Hill is distinguished from this case. In contrast to the objectionable testimony in Hill, Lanier’s statements were not deliberately elicited by the prosecutor as blatant attacks on Crowder’s credibility.” 2. INVOCATION OF RIGHT TO SILENCE Seminal case: Berghuis v. Thompkins , 560 U.S. 370, 130 S.Ct. 2250, 176 L.Ed.2d 1098 (June 1, 2010) ( see below ).