of criminal activity and that the officers’ actions in this case “were appropriate to protect both themselves and the bystanders from the dangers involved in a narcotics arrest.” Although we find few circumstances under which Fourth Amendment seizures are justified in the absence of probable cause or reasonable suspicion of criminal activity, we disagree with appellant’s contention that the absence of probable cause or reasonable suspicion of criminal activity renders a police-initiated detention unlawful per se. See Maryland v. Wilson, — U.S.-, 117 S.Ct. 882, 137 L.Ed.2d 41 (1997); Michigan v. Summers, 452 U.S. 692, 101 S.Ct. 2587, 69 L.Ed.2d 340 (1981). In Wilson, the Supreme Court extended the rationale of Pennsylvania v. Mimms, 434 U.S. 106, 98 S.Ct. 330, 54 L.Ed.2d 331 (1977) (<HOLDING>), and held that a police officer making a
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 the officer acted within the scope of his authority in requiring the defendant stopped in middle lane of traffic to exit his vehicle 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 officer may order driver out of vehicle once lawfully detained for traffic violation holding that once a vehicle has been lawfully stopped an officer may order the driver out of the vehicle without violating the fourth amendment