Farm Bureau Ins. Co., 773 S.W.2d 391, 393 (Tex.App.-Dallas 1989, writ denied)). 8 . See Gen. Accident Ins. Co. v. D’Alessandro, 671 A.2d 1233, 1235 (R.I.1996) (requiring (1) causal connection between injury and insured vehicle, (2) reasonably close geographic proximity to vehicle, (3) vehicle-orientation rather than highway-orientation or sidewalk-orientation, and (4) engagement in transaction essential to use of the vehicle); Kentucky Farm Bureau Mut. Ins. Co. v. McKinney, 831 S.W.2d 164, 168 (Ky.1992) (same); Utica Mut. Ins. v. Contrisciane, 504 Pa. 328, 473 A.2d 1005, 1009 (1984) (same). 9 . See Butzberger v. Foster, 151 Wash.2d 396, 89 P.3d 689, 696 (2004) (rejecting fourth prong of four-prong test). 10 . See Olsen v. Farm Bureau Ins. Co., 259 Neb. 329, 609 N.W.2d 664, 670 (2000) (<HOLDING>); Joins v. Bonner, 28 Ohio St.3d 398, 504
holding that after making an arrest of the driver of a vehicle the police may search the passenger compartment of the vehicle holding a car was broken into or entered when defendant reached in through the open window of a car holding passenger was in the process of getting out of vehicle until he reached a position of safety away from the car holding that police officer was not justified in detaining a passenger who exited and began to walk away from a lawfully stopped vehicle absent an articulated reason as to why it was necessary to detain the passenger for the officers safety holding an officer may order a passenger to get out of a car during a traffic stop and may frisk a passenger for weapons if the officer reasonably suspects the passenger is armed and dangerous