673 (citing Florida v. Royer, 460 U.S. 491, 103 S.Ct. 1319, 75 L.Ed.2d 229 (1983)). Viewing these behaviors together under a totality of the circumstances analysis, the court finds that a reasonable factfinder could conclude that the officers lacked reasonable suspicion that criminal activity was afoot. And so, at the outset and absent any conduct by Lee and his passengers during the stop that would give the officers reasonable suspicion or probable cause to further detain them, the traffic stop should have been limited in scope to the routine procedures described in Rusher. The court notes that it is not unreasonable for an officer to ask a driver to step out of the vehicle during the course of the stop. See Pennsylvania v. Mimms, 434 U.S. 106, 111, 98 S.Ct. 330, 54 L.Ed.2d 331 (1977) (<HOLDING>). And so, it was not unreasonable for the
holding that once a vehicle has been lawfully stopped an officer may order the driver out of the vehicle without violating the fourth amendment holding that the additional intrusion into a drivers personal liberty by an order to step out of the vehicle after having been stopped for a traffic violation is de minimus holding that officer may order driver out of vehicle once lawfully detained for traffic violation holding that for general safety purposes an officer may routinely order the driver of a lawfully stopped vehicle to exit the vehicle because when the vehicle is already stopped the slight additional intrusion associated with being directed to exit the car can only be described as de minimis holding police officers making a traffic stop could order passengers out of the stopped car