In 2009, the Supreme Court extended the stop-and frisk authority by ruling that a police officer can order a passenger in a car that has been pulled over for a traffic violation to submit to a pat-down.

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The Supreme Court's decision in Arizona v. Johnson (2009) allowed officers to frisk passengers during a traffic stop if they have reasonable suspicion that the person is armed and dangerous.

In 2009, the Supreme Court Extended the Stop-And Frisk Authority