Pennsylvania v. Mimms

The key to any Fourth Amendment analysis is whether the challenged conduct was reasonable. The reasonableness of conduct depends on “a balance between the public interest and the individual’s right to personal security free from arbitrary interference by police officers.” With regard to the first issue, the safety of an officer is a legitimate and weighty concern (officer will not have to stand near traffic flow, etc.) that outweighs the minimal intrusion suffered by a driver who is asked to get out of a lawfully stopped car. With regard to the second issue, the Court’s decision in Terry v. Ohio was controlling. “The bulge in the defendant’s jacket permitted the officer to conclude that the defendant was armed and thus posed a serious and present danger to the safety of the officers.”