Edgell v. State

In Edgell v. State, 253 Ga. App. 775, 777 (560 SE2d 532) (2002), the officer had already issued a traffic citation and was about to impound the vehicle, and the defendant was leaving. The officer frisked him when he stepped out of the car because he always frisked people who exited a vehicle. Id. at 776. The Court held that the officer had no reasonable basis to conclude Edgell was armed or dangerous or even to detain him.