a suspected crime.”); State v. Mendez, 137 Wash.2d 208, 970 P.2d 722, 728 (1999) (“An officer must therefore be able to articulate an objective rationale predicated specifically on safety concerns, for officers, vehicle occupants, or other citizens, for ordering a passenger to stay in the vehicle or to exit the vehicle to satisfy article I, section 7.”); Commonwealth v. Gonsalves, 429 Mass. 658, 711 N.E.2d 108, 112 (1999) (“[W]e conclude that art. 14 requires that a police officer, in a routine traffic stop tection under the state’s constitutional provision because they conclude that the officer’s order to exit and/or remain in a vehicle is not a minimal intrusion upon an individual or that it constitutes a separate and distinct seizure. See, e.g., Sprague, 824 A.2d at 544-45 (<HOLDING>); Gonsalves, 711 N.E.2d at 112 (stating that an
holding that the officer acted within the scope of his authority in requiring the defendant stopped in middle lane of traffic to exit his vehicle recognizing that an order to exit ones vehicle is a further seizure within the meaning of article eleven 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 that a police officer may as a matter of course order the driver of a lawfully stopped car to exit his vehicle holding that a state is not a person within the meaning of  1983