Cann-Hanson v. State

In Cann-Hanson v. State, 223 Ga. App. 690 (478 SE2d 460) (1996), the Court noted that "[e]ven in the absence of the field sobriety tests, the officer's observation that Cann-Hanson had bloodshot, watery eyes and exuded an odor of alcohol was sufficient to show probable cause to arrest him for driving under the influence." Id. at 691 (1). Similarly, in Frederick v. State, 270 Ga.App. 397, 397-398, 606 S.E.2d 615 (2004) at 398, the defendant admitted that he had been drinking, and the officer smelled a strong odor of alcohol on the defendant's person and observed that the defendant's eyes were glassy. Id. The Court held that the arresting officer had probable cause to arrest for less safe DUI. Id.