they were not suspected of any criminal activity. Particularly where, as here, an officer initiates an investigatory encounter based on some suspicious circumstances, the officer could easily feel threatened by an armed person and be justified in conducting a frisk. “The danger to officer safety that justifies a protective search” may arise even during a consensual encounter. United States v. Davis, 202 F.3d 1060, 1063 (8th Cir.2000). Other situations could also lead an officer to fear for his safety during a consensual encounter. For example, a person might become belligerent or show signs of mental instability during a consensual encounter, even if the person’s actions do not give rise to suspicion of criminal activity. See United States v. Brown, 232 F.3d 589, 593-95 (7th Cir.2000) (<HOLDING>). Not every threatening action is criminalized,
holding that a threat to harm another person is a crime of violence holding that threat occurring 36 days before possession of firearm not present threat holding a reasonable officer could perceive a threat to his safety from a potentially drunk person acting erratically holding that when the officer has a reasonable suspicion that illegal drugs are in the vehicle the officer may in the absence of factors allaying his safety concerns order the occupants out of the vehicle and pat them down briefly for weapons to ensure the officers safety and the safety of others holding that a motion to strike was improper where defendant assisted a drunk minor in his negligence by driving the drunk minor to his car