stopped vehicle inquiry in Georgia

2016“Miranda warnings are required only if the detention has ripened into a custodial arrest.” (Citations omitted; emphasis in original.) Abrahamson v. State, 276 Ga. App. 584, 585 ( 623 SE2d 764 ) (2005). “[A]n officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first type of police-citizen encounter.” (Punctuation and footnote omitted.) Bacallao v. State, 307 Ga. App. 539, 541 ( 705 SE2d 307 ) (2011).

2016“Miranda warnings are required only if the detention has ripened into a custodial arrest.” (Citations omitted; emphasis in original.) Abrahamson v. State, 276 Ga. App. 584, 585 ( 623 SE2d 764 ) (2005). “[A]n officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first type of police-citizen encounter.” (Punctuation and footnote omitted.) Bacallao v. State, 307 Ga. App. 539, 541 ( 705 SE2d 307 ) (2011).

2013“It is well-established that an officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first tier of police-citizen encounter[s].” (Citation and punctuation omitted.) Akins, supra, 266 Ga. App. at 215 (1).

2013“It is well-established that an officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first tier of police-citizen encounter[s].” (Citation and punctuation omitted.) Akins, supra, 266 Ga. App. at 215 (1).

2012Generally, “an officer’s approach to a stopped vehicle and inquiry into the situation are not a ‘stop’ or ‘seizure’ but rather clearly fall within the realm of the first type of police-citizen encounter.” (Citations and punctuation omitted.) Carrera v. State, 261 Ga. App. 832, 834 ( 584 SE2d 2 ) (2003); see also Palmer v. State, 257 Ga. App. 650, 651-652 (1) ( 572 SE2d 27 ) (2002).

2012Generally, “an officer’s approach to a stopped vehicle and inquiry into the situation are not a ‘stop’ or ‘seizure’ but rather clearly fall within the realm of the first type of police-citizen encounter.” (Citations and punctuation omitted.) Carrera v. State, 261 Ga. App. 832, 834 ( 584 SE2d 2 ) (2003); see also Palmer v. State, 257 Ga. App. 650, 651-652 (1) ( 572 SE2d 27 ) (2002).

2004Pretermitting whether Akins has standing to raise this issue, “[i]t is well established that an officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first [tier] of police-citizen encounter.” (Citation and punctuation omitted.) Stokes v. State, 238 Ga. App. 230, 232 ( 518 SE2d 447 ) (1999).

2004Pretermitting whether Akins has standing to raise this issue, “[i]t is well established that an officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first [tier] of police-citizen encounter.” (Citation and punctuation omitted.) Stokes v. State, 238 Ga. App. 230, 232 ( 518 SE2d 447 ) (1999).

2013During this first-tier encounter, the officer was permitted to “ask [Pierce] to roll down a window or step out of a car, and freely question [her] without any articulable suspicion, as long as the officer [ ] [did] not detain [her] or create the impression that [she] may not leave.” (Citation and punctuation omitted.) Id. at 216 (1); see also Mauge v. State, 279 Ga. App. 36, 38 ( 630 SE2d 174 ) (2006).

2013During this first-tier encounter, the officer was permitted to “ask [Pierce] to roll down a window or step out of a car, and freely question [her] without any articulable suspicion, as long as the officer [ ] [did] not detain [her] or create the impression that [she] may not leave.” (Citation and punctuation omitted.) Id. at 216 (1); see also Mauge v. State, 279 Ga. App. 36, 38 ( 630 SE2d 174 ) (2006).

2012Generally, “an officer’s approach to a stopped vehicle and inquiry into the situation are not a ‘stop’ or ‘seizure’ but rather clearly fall within the realm of the first type of police-citizen encounter.” (Citations and punctuation omitted.) Carrera v. State, 261 Ga. App. 832, 834 ( 584 SE2d 2 ) (2003); see also Palmer v. State, 257 Ga. App. 650, 651-652 (1) ( 572 SE2d 27 ) (2002).

2012Generally, “an officer’s approach to a stopped vehicle and inquiry into the situation are not a ‘stop’ or ‘seizure’ but rather clearly fall within the realm of the first type of police-citizen encounter.” (Citations and punctuation omitted.) Carrera v. State, 261 Ga. App. 832, 834 ( 584 SE2d 2 ) (2003); see also Palmer v. State, 257 Ga. App. 650, 651-652 (1) ( 572 SE2d 27 ) (2002).

1999It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a “stop” or “seizure” and “clearly fall[s] within the realm of the first type of police-citizen encounter.” McClain v. State, 226 Ga. App. 714, 716 (1) ( 487 SE2d 471 ) (1997).

1999It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a “stop” or “seizure” and “clearly fall[s] within the realm of the first type of police-citizen encounter.” McClain v. State, 226 Ga. App. 714, 716 (1) ( 487 SE2d 471 ) (1997).

2004“It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a ‘stop’ or ‘seizure’ and ‘clearly falls within the realm of the first type of police-citizen encounter.’ ” (Citation omitted.) State v. Folk, 238 Ga. App. 206, 207 ( 521 SE2d 194 ) (1999).

2004“It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a ‘stop’ or ‘seizure’ and ‘clearly falls within the realm of the first type of police-citizen encounter.’ ” (Citation omitted.) State v. Folk, 238 Ga. App. 206, 207 ( 521 SE2d 194 ) (1999).

2016“It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a stop or seizure and clearly falls within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Whitmore v. State, 289 Ga. App. 107, 109 ( 657 SE2d 1 ) (2008); Chapman v. State, 279 Ga. App. 200, 202 (1) ( 630 SE2d 810 ) (2006).

2016“It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a stop or seizure and clearly falls within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Whitmore v. State, 289 Ga. App. 107, 109 ( 657 SE2d 1 ) (2008); Chapman v. State, 279 Ga. App. 200, 202 (1) ( 630 SE2d 810 ) (2006).

2008(Punctuation and footnotes omitted.) Id. at 239 .

2003“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation [are] not a ‘stop’ or ‘seizure’ but rather clearly fall[ ] within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Stokes, supra, 238 Ga. App. at 232 ; accord Hutto, supra, 259 Ga. App. at 239 ; see Mijares, supra, 252 Ga. App. at 805 (2) (police approaching parked car is first-tier encounter); Voyles, supra, 237 Ga. App. at 887 (1) (same).

2017“It is well established that an officer’s approach to a stopped vehicle and inquiry as to what is going on do not constitute a ‘stop’ or ‘seizure’ and clearly falls within the realm of the first type of police-citizen encounter.” In the Interest of A. A., 265 Ga. App. 369, 371 (1) ( 593 SE2d 891 ) (2004) (citation and punctuation omitted).

2017“It is well established that an officer’s approach to a stopped vehicle and inquiry as to what is going on do not constitute a ‘stop’ or ‘seizure’ and clearly falls within the realm of the first type of police-citizen encounter.” In the Interest of A. A., 265 Ga. App. 369, 371 (1) ( 593 SE2d 891 ) (2004) (citation and punctuation omitted).

2016“It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a stop or seizure and clearly falls within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Whitmore v. State, 289 Ga. App. 107, 109 ( 657 SE2d 1 ) (2008); Chapman v. State, 279 Ga. App. 200, 202 (1) ( 630 SE2d 810 ) (2006).

2016“It is well established that an officer’s approach of a stopped vehicle and inquiry as to what is going on does not constitute a stop or seizure and clearly falls within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Whitmore v. State, 289 Ga. App. 107, 109 ( 657 SE2d 1 ) (2008); Chapman v. State, 279 Ga. App. 200, 202 (1) ( 630 SE2d 810 ) (2006).

2016“Miranda warnings are required only if the detention has ripened into a custodial arrest.” (Citations omitted; emphasis in original.) Abrahamson v. State, 276 Ga. App. 584, 585 ( 623 SE2d 764 ) (2005). “[A]n officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first type of police-citizen encounter.” (Punctuation and footnote omitted.) Bacallao v. State, 307 Ga. App. 539, 541 ( 705 SE2d 307 ) (2011).

2016“Miranda warnings are required only if the detention has ripened into a custodial arrest.” (Citations omitted; emphasis in original.) Abrahamson v. State, 276 Ga. App. 584, 585 ( 623 SE2d 764 ) (2005). “[A]n officer’s approach to a stopped vehicle and inquiry into the situation is not a ‘stop’ or ‘seizure’ but rather clearly falls within the realm of the first type of police-citizen encounter.” (Punctuation and footnote omitted.) Bacallao v. State, 307 Ga. App. 539, 541 ( 705 SE2d 307 ) (2011).

2016See also Walker, 295 Ga. at 890-891 .

2009“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation are not a stop or seizure but rather clearly fall within the realm of the first type of police-citizen encounter.” (Citations and punctuation omitted.) Collier v. State, 282 Ga. App. 605, 607 ( 639 SE2d 405 ) (2006).

2009“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation are not a stop or seizure but rather clearly fall within the realm of the first type of police-citizen encounter.” (Citations and punctuation omitted.) Collier v. State, 282 Ga. App. 605, 607 ( 639 SE2d 405 ) (2006).

2003“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation [are] not a ‘stop’ or ‘seizure’ but rather clearly fall[ ] within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Stokes, supra, 238 Ga. App. at 232 ; accord Hutto, supra, 259 Ga. App. at 239 ; see Mijares, supra, 252 Ga. App. at 805 (2) (police approaching parked car is first-tier encounter); Voyles, supra, 237 Ga. App. at 887 (1) (same).

2003“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation [are] not a ‘stop’ or ‘seizure’ but rather clearly fall[ ] within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Stokes, supra, 238 Ga. App. at 232 ; accord Hutto, supra, 259 Ga. App. at 239 ; see Mijares, supra, 252 Ga. App. at 805 (2) (police approaching parked car is first-tier encounter); Voyles, supra, 237 Ga. App. at 887 (1) (same).

2003“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation [are] not a ‘stop’ or ‘seizure’ but rather clearly fall[ ] within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Stokes, supra, 238 Ga. App. at 232 ; accord Hutto, supra, 259 Ga. App. at 239 ; see Mijares, supra, 252 Ga. App. at 805 (2) (police approaching parked car is first-tier encounter); Voyles, supra, 237 Ga. App. at 887 (1) (same).

2003“It is well established that an officer’s approach to a stopped vehicle and inquiry into the situation [are] not a ‘stop’ or ‘seizure’ but rather clearly fall[ ] within the realm of the first type of police-citizen encounter.” (Citation and punctuation omitted.) Stokes, supra, 238 Ga. App. at 232 ; accord Hutto, supra, 259 Ga. App. at 239 ; see Mijares, supra, 252 Ga. App. at 805 (2) (police approaching parked car is first-tier encounter); Voyles, supra, 237 Ga. App. at 887 (1) (same).