be the shooter (and, therefore, might be carrying a gun). Upon being asked to exit the vehicle, the defendant balked; instead of exiting, he uttered more profanity, further heightening Officer Hyland’s legitimate concerns. Even without that further incitement, the pat-frisk would have been permissible. Once an officer has formed a reasonable belief that a detained person may be armed and dangerous, a pat-down for protective purposes is, without more, deemed reasonably related in scope to the stop. See Terry, 392 U.S. at 30, 88 S.Ct. 1868; United States v. Ivery, 427 F.3d 69, 72 (1st Cir.2005). Thus, when the defendant refused to accede to Officer Hyland’s request, the officers were constitutionally entitled to remove him from the vehicle and pat-frisk him. See Soares, 521 F.3d at 121 (<HOLDING>). The defendant discourages this holding and
holding removal from car and patfrisk constitutional when defendant among other things refused to remain still and used profanity 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 on habeas review that defendant was not in custody for miranda purposes and reciting among other facts that defendant was transported to a police station for questioning in an unmarked police car which was not equipped with a shield inside the car holding drug addiction admissible to show motive to rob and kill when defendant had the victims car check book and credit cards told his wife and a friend that he had killed the victim in selfdefense sold the car to a drug dealer and used all the money from forged checks credit card cash advances and car sale to purchase and use drugs holding that defendant violated  148a1 when he refused officers repeated requests to step away from the patrol car