Heitkamp v. the State, 342 Ga. App. 674

Officers responded to a 911 call from an apartment maintenance man reporting a suspicious white (stolen) vehicle and heavy foot traffic suggesting drug activity; the caller described the occupant as a "white male, wearing jeans, no shirt, and tattoos."
Police ran the tag en route and learned the vehicle was reported stolen, then knocked on doors of the 3800 building to investigate.
At one apartment, Heitkamp opened the door; a tan dog exited, two white males moved further into the unit, and one (Barfield) matched the vague description (white, jeans, visible arm tattoos) and retreated into the apartment.
Officers entered the apartment without a warrant, observed methamphetamine in plain view, secured the scene, obtained a search warrant, patted down occupants, and after consent to search Heitkamp found meth in his pocket; subsequent warrant search yielded additional drugs and paraphernalia.
Heitkamp moved to suppress all evidence as the product of an unlawful warrantless entry; the trial court denied the motion and the Court of Appeals granted interlocutory review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had probable cause to enter the apartment and arrest occupants based on the tip and occupants' flight	Heitkamp: tip + flight did not give particularized probable cause to believe Barfield (or others) committed theft of the stolen car; entry thus violated the Fourth Amendment	State: caller’s description, vehicle reported stolen, matching occupant, and flight provided probable cause and justified immediate entry	Court: No probable cause. Tip was vague and not reliably particularized to Barfield; flight alone insufficient; warrantless entry violated the Fourth Amendment

Leming v. State, 235 Ga. App. 710 (trial court factual findings on suppression are reviewed for clear error)
State v. Bowen, 231 Ga. App. 95 (credibility and disputed facts deference on suppression)
Snider v. State, 292 Ga. App. 180 (both probable cause and exigent circumstances needed for warrantless entry into lodging)
State v. Sims, 240 Ga. App. 391 (residence enjoys heightened Fourth Amendment protection; warrantless intrusion requires exigency)
Brown v. State, 262 Ga. 728 (definition of probable cause for arrest)
Hughes v. State, 296 Ga. 744 (probable cause assessed from facts known to officer at the time)
Elvine v. State, 334 Ga. App. 235 (probable cause is based on totality of circumstances; must be particularized)
Lopez v. State, 292 Ga. App. 518 (reliability and basis-of-knowledge of informant tip assessed together)
Ansley v. State, 325 Ga. App. 226 (detailed descriptive tip supporting probable cause)
Harris v. State, 205 Ga. App. 813 (flight alone insufficient to justify forcible stop)
In the Interest of J. L. G., 209 Ga. App. 565 (flight plus corroborating circumstances can support probable cause, but defendant was not in home)
Ewumi v. State, 315 Ga. App. 656 (mere presence in a high-crime area insufficient for particularized suspicion)
Powell v. State, 163 Ga. App. 801 (mere proximity to suspected drug area insufficient for arrest)