Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
Protective sweep of a vehicle's passenger compartment (vehicle frisk)
Leading case
Michigan v. Long, 463 U.S. 1032 (1983)
How courts have described it
comparing a protective sweep in this circumstance to a Terry stop because “if the suspect is not placed under arrest, he will be permitted to reenter his automobile, and he will then have access to any weapons inside”
United States v. Williams (10th Cir. 2026)
holding that contraband discovered during a legitimate search for weapons need not be suppressed under the Fourth Amendment
United States v. Arnott, 758 F.3d 40 (1st Cir. 2014)
holding the protective sweep of a glove box reasonable under Terry when officer had a reasonable belief that the suspect was potentially dangerous
United States v. Dale Washington Orman, 486 F.3d 1170 (9th Cir. 2007)
recognizing that a Terry suspect could break away from police control and retrieve a weapon from the car
United States v. Christopher L. Scott, 72 F.3d 139 (10th Cir. 1995)
holding that police may engage in warrantless “frisks” of vehicles when they have reasonable belief that driver poses danger and that weapon may be inside car
United States v. Robert Ryles, Jr., 988 F.2d 13 (5th Cir. 1993)
recognizing that individuals “may injure police officers and others by virtue of their access to weapons, even though they may not themselves be armed,”
Norman v. Horton (E.D. Ky. 2025)
recognizing that roadside stops are “especially hazardous” and “especially fraught with danger to police officers”
Williams III v. Mallet, Jr. (S.D. Fla. 2023)
protective sweep of vehicle permissible during Terry stop where reasonable concern for safety exists
David Allen Cronin v. State (Tex. App. 2005)
holding that protection of police can justify protective searches when police have a reasonable belief that the suspect poses a danger
Mark Wilson Glazner v. State (Tex. App. 2004)
holding that officer entitled to do a protective sweep of car’s interior in search for weapons where officer has reasonable belief that car’s occupant dangerous
Johnson v. State, 47 S.W.3d 701 (Tex. App. 2001)
holding that protective search of passenger compartment was reasonable under the principles articulated in Terry and other decisions of the United States Supreme Court
Commonwealth v. Rosa, 734 A.2d 412 (Pa. Super. Ct. 1999)
Related doctrines
- Informant's tip as reasonable suspicion for Terry stop and protective frisk
- Reasonable, Articulable Suspicion for Stops and Frisks
- Terry frisk scope — pat-down prerequisite to pocket intrusion
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.