Does a limited protective search following a traffic stop constitute a reasonable search?

"New York", United States of America

The following excerpt is from People v. Hardee, 30 N.Y.3d 991, 66 N.Y.S.3d 196, 88 N.E.3d 354 (N.Y. 2017):

Subsequently, in People v. Carvey, we upheld as lawful a limited protective search following a traffic stop where, after the defendant had been removed from the vehicle and patted down, it was determined that he was wearing a bulletproof vest (see

[88 N.E.3d 358]

[66 N.Y.S.3d 200]

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