I thought that case law (limited jurisdiction? IDK) was that passengers were only detained during a vehicle stop if there was RAS which applied to them individually. In other words, if the only RAS/PC for any stop was that the officer observed the car turn without using a blinker, only the driver could be lawfully detained. In such a case, the passenger would be free to decline to identify and even leave if they so chose. Obviously the passenger isn't responsible for blinker usage. If the officer got to the window of the vehicle and observed a bag of what appeared to be an illegal narcotic on the floor, then he might seize all occupants, since that RAS/PC might apply to everyone within the vehicle.
I remember reading about this but I have no recollection of the case. Perhaps someone with better memory knows what I'm talking about?
Been researching, I'm probably wrong. Looks like the police get their way far too often in court rulings for the generic "officer safety" falsehood. Then again, I was reading on policeone, where they are unabashedly pro-police-state, and proudly twist court rulings to their favor (don't worry, this case doesn't really expand the people's rights, just read between the lines they say).
First, I'm going from memory, and foggy memory at that, so take this as a suggestion that things
might be this way, and keep hunting for cases if interested.
I think what we're looking at first of all is a difference in types of cases. Not all that many CCW permit holders have been cited under this statute, convicted, and then appealed to have binding case law handed down by an appellate court. Most of the stopped vs detained cases I've read were for some criminal conduct where the court was sorting out whether the evidence discovered on the passenger was the fruit of a poisonous tree/suppressible. For example, the cop stops the car for window tint as a pretext, but he suspects he saw a hand-to-hand drug sale while the car was stopped at a traffic light a couple blocks back. The passenger gets out and starts walking away as soon as the car is stopped. Did the cop have RAS to hold the passenger? To search him for officer safety and find the drugs? You get the idea. Totally different types of cases.
Thus, I suspect, there are distinctions. Whether a passenger is initially seized by the flashing lights of the cop car is pretty clear from my reading of cases (he is; but, that may only be recognition by the courts that he just happens to be in that vehicle and can't avoid being stopped or exercising refused consent.) But, I think it then comes down to whether the cop has reason to compel the passenger to remain. I've read the summary of at least one (state?) case where the cop had to let a passenger walk away when the cop didn't have RAS against the passenger. But, I've read another case summary where the cop was ruled in-bounds by handcuffing a passenger for officer safety while an inventory search was performed on the car.
Now, the Michigan statute does not distinguish whether the CCW passenger has enough RAS against him to seize him personally. The statute merely says "stopped". Not stopped and held.
Overall, I think its a gray area, betting there is very little, if any, case law directly on point.