California, United States of America
The following excerpt is from People v. Brisendine, 119 Cal.Rptr. 315, 13 Cal.3d 528, 531 P.2d 1099 (Cal. 1975):
9 The few post-Simon cases dealing with this issue have so held. For example, in People v. Ramos (1972) 26 Cal.App.3d 108, 102 Cal.Rptr. 502, a pat-down of a hit-and-run suspect was conducted prior to placing him in a police vehicle for transportation back to the scene of the accident. The search uncovered a switchblade knife, and the defendant was arrested for its possession. The defendant was not under arrest at the time of the search, but the fact of transportation in the police vehicle was held sufficient to justify the pat-down.
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