The Terry standard still applies, as I understand this ruling - not that it is always strictly observed in traffic stops. I've had cops pat me down, invoking "officer safety" as the excuse, absent any particular suspicion of wrongdoing on my part. My suggestion that they should have gone into primary education if they were so concerned for their safety was not well received. Falls under "assumption of the risk" as far as I'm concerned. They want to live by the sword -let them take their chances. I don't mean to trivialize their legitimate safety concerns, but the 4th amendment exists for a reason, and it is not a "technicality," or ought not to be anyway.