the driver and/or the passenger to take advantage of a distracted officer. Balancing the competing interests does not require us to ignore real dangers to officers, especially in light of the minimal intrusion. Id. at 1034 (citations omitted). ¶ 20 We are cognizant that in the cases cited above, the officer was acting alone, while in the instant case, two officers were present. However, we do not believe this distinction compels a contrary result, in that the purpose of allowing an officer to require a passenger to remain in or reenter a vehicle is to facilitate the officer’s control of the situation, which we do not find necessarily dependent on the ratio between officers and vehicle occupants. See, e.g., United States v. Hampton, 2007 WL 1139586 (W.D.Pa. filed April 12, 2007) (<HOLDING>). ¶ 21 We also recognize that certain state
holding that fourth amendment rights of a passenger of a legally stopped vehicle were not violated by police officers instruction that he remain inside the vehicle during traffic stop after passenger repeatedly tried to exit 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 holding that a passenger ordered by police to get back onto the vehicle that she voluntarily exited was not an unreasonable seizure because a police officer has the power to reasonably control the situation by requiring a passenger to remain in a vehicle during a traffic stop holding that an officer may order a passenger out of a vehicle during a stop for a traffic infraction holding that after making an arrest of the driver of a vehicle the police may search the passenger compartment of the vehicle