passenger’s door and ordered Garcia out of the car. See Pennsylvania v. Mimms, 434 U.S. 106, 111-12, 98 S.Ct. 330, 54 L.Ed.2d 331 (1977) (police may order driver out of car during an otherwise legal traffic stop); Maryland v. Wilson, 519 U.S. 408, 410, 117 S.Ct. 882, 137 L.Ed.2d 41 (1997) (extending Mimms to passengers); Mollica v. Volker, 229 F.3d 366, 369 (2d Cir.2000) (“We focus first on the constitutionality of the initial stop because if a stop is lawful, passengers and drivers have no Fourth Amendment interest in not being ordered out of the stopped vehicle.”); Dhinsa, 171 F.3d at 723 (noting that, in course of legal stop, the officer “took [defendant’s] car keys [and] opened the passenger-side front door”); People v. Edwards, 222 A.D.2d 603, 635 N.Y.S.2d 274, 275 (2d Dep’t 1995) (<HOLDING>); People v. Vasquez, 106 A.D.2d 327, 483
holding that an unconstitutional seizure occurred when police officers discovered that a suspect illegally sold alcohol from his home and ordered him to open the door involuntarily to be arrested inside his home holding that there was probable cause for arrest where officers knew defendants had recently been with suspected drug dealer officers saw defendants car being maneuvered so as to indicate that surveillance had been detected and when officers approached car defendant attempted to place package under car and then pulled the package back inside the car and closed and locked the car door holding that officers were permitted to open door after stopping car for illegally tinted windows recognizing that officers making initial contact with driver of car who was lawfully parked late at night in a park was an appropriate welfare check where officer testified he was concerned because towels were obscuring the car windows holding that since the officer was entitled to order defendant out of the car he was equally entitled to open the door to accomplish that object