Court of Appeals of Georgia November 21, 1990, A90A1557 (Howard v. State)

McMurray, Presiding Judge.

Law enforcement officers were conducting a surveillance of the residence of a known drug dealer in an attempt to determine the identity of the dealer’s supplier of methamphetamine. Defendant was observed driving past the residence and throwing out a plastic bag onto the driveway containing approximately 28 grams of methamphetamine.