must have a reasonable belief that the officer’s safety, or the safety of others, is in danger before ordering a driver out of a motor vehicle. The fact that we do not follow Mimms [II] in this type of case necessarily leads to the conclusion that we shall not follow Wilson either, because Wilson extends Mimms [II] in a manner incompatible with the rights guaranteed Massachusetts citizens under art. 14.”); State v. Smith, 134 N.J. 599, 637 A.2d 158, 166 (1994) (concluding that under Article I, Paragraph 7 of the New Jersey Constitution, an officer must have “some quantum of individualized suspicion” before asking a passenger to step out of a vehicle, because the request, although not a major intrusion, is nevertheless an intrusion); State v. Kim, 68 Haw. 286, 711 P.2d 1291, 1294 (1985) (<HOLDING>). In general, these decisions provide broader
holding that under article i section 7 of the hawaii constitution a police officer must have at least a reasonable basis of specific articulable facts to believe a crime has been committed to order a driver out of a car after a traffic stop holding that a traffic stop is valid under the fourth amendment if the stop is based on an observed traffic violation or if the police officer has reasonable articulable suspicion that a traffic or equipment violation has occurred or is occurring holding that a police officer may stop a driver where the officer has a reasonable and articulable suspicion regarding the commission of a civil traffic violation holding that a traffic stop is reasonable under the fourth amendment when police have probable cause to believe a traffic infraction has occurred holding that when a police communique has been issued on the basis of articulable facts supporting a reasonable suspicion any authorized officer may make an investigatory stop on the basis of that bulletin even though the officer making the stop is not aware of the underlying facts