The following excerpt is from U.S. v. Ricardo D., 912 F.2d 337 (9th Cir. 1990):
Other circuits addressing the patrol car issue have relied on similar justifications for upholding the detention as a mere investigatory stop. See, e.g., Manbeck, 744 F.2d 377-78 (defendant would have had possible access to weapons and a means of escape if allowed to remain in his own truck, and due to inclement weather, placement in patrol car was only feasible alternative); United States v. Lego, 855 F.2d 542, 545 (8th Cir.1988) (because suspect already found to have a weapon, safety concerns made it proper for lone officer to have suspect sit in patrol car while officer ran a check for outstanding warrants).
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