The State appealed after a trial court suppressed Paul Richards’s statements and evidence found in his truck following a police encounter at a gas station near Georgia Tech. An officer approached Richards while he was seated in the truck, asked about drug use, and asked whether he would show his arms; Richards then consented to searches that uncovered cash and ketamine. The Georgia Court of Appeals majority held that the initial interaction was a first-tier police-citizen encounter, not a seizure, because the officer’s request was not accompanied by a threat, force, touching, or a blocked exit. The majority therefore reversed the suppression ruling insofar as it rested on the request to show Richards’s arms. Because the trial court had not considered whether the arrival of additional officers affected the voluntariness of Richards’s later consent, the Court remanded that issue for further findings. Judge Miller, joined by Presiding Judge Barnes, dissented, reasoning that the armed backup officers and possible blocked exit created an unlawful second-tier detention and tainted the consent and statements.