In Georgia, there are three tiers of police-citizen encounters: 'police-citizen communications involving no coercion or detention; brief seizures that must be supported by reasonable suspicion; and arrests that must be supported by probable cause.'" Martin v. State, 291 Ga. App. 363, 364 (1) (a) (662 SE2d 185) (2008). In a first-tier encounter, police may approach citizens, ask for identification, ask for consent to search, and otherwise freely question the citizen without any basis or belief of criminal activity so long as a reasonable person would feel free to decline the officers' request or otherwise terminate the encounter. A request to search during a first-tier encounter does not require articulable suspicion. Bryant v. State, 288 Ga. App. 863, 866-867 (1) (a) (655 SE2d 707) (2007).