Apparent hand-to-hand transaction alone from a car not enough for stop, but here there was more

Defendant challenged his stop and arrest based on what appeared to be a hand to hand transaction. The alleged transaction alone was not enough to stop defendant in a high crime area, but there was a basis for a traffic stop, and that led to a request for consent. A drug dog was also lawfully used. Thomas v. State, 289 Ga. App. 161, 657 S.E.2d 247 (2008).*

Defendant’s stop was justified by reasonable suspicion, and defendant filed an Anders brief on the merits. State v. Brocksmith, 2008 Ohio 31, 2008 Ohio App. LEXIS 21 (5th Dist. January 7, 2008).*

Defendant argued that “similar transaction” evidence was inadmissible because it was unlawfully obtained [apparently not arguing that it was inadmissible as 404(b) evidence or more prejudicial than relevant], but it was lawfully obtained, so it comes in. Sherrer v. State, 289 Ga. App. 156, 656 S.E.2d 258 (2008).*

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