The State appealed an order suppressing Michael Lloyd Williams’s statement after his arrest for obstruction. The Court of Appeals of Georgia held that the investigating deputy had probable cause to arrest Williams. The deputy’s order to stop was a lawful brief investigatory detention supported by articulable suspicion, and Williams’s continued flight after that order supplied probable cause for obstruction. The trial court therefore erred in concluding that the deputy lacked probable cause. The appellate court reversed the suppression ruling. Judge Miller concurred in the judgment only.