What is the legal test for a search of a vehicle by a police officer who has probable cause to believe that a crime has been committed?

Wyoming v. Houghton held that the existence of probable cause to search a vehicle justified the search of any portion of the vehicle or any container therein that might hold contraband or evidence of the suspected criminal activity. It is fundamentally different to say that a concern for officer safety that justifies the search of a vehicle itself justifies, in all circumstances, the search of any place or anything in the vehicle that might contain a weapon. Once an officer has probable cause to believe that a crime has been committed, as in Wyoming v. Houghton, the justification for the search is established and the search proceeds. A search justified by a concern for officer safety or the safety of the public must be based on circumstances

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In Terry v. Ohio (1968) 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 the United States Supreme Court held "... where a police officer observes unusual conduct which leads him reasonably to conclude in light of his experience that criminal activity may be afoot and that the persons with whom he is dealing may be armed and presently dangerous; where in the course of investigating this behavior he identifies himself as a policeman and makes reasonable inquiries; and where nothing in the initial stages of the encounter serves to dispel his reasonable fear for his own or others' safety, he is entitled for the protection of himself and others in the area to conduct a carefully limited search of the outer clothing of such persons in an attempt to discover weapons which might be used to assault him." (Id. at pp. 30-31, 88 S.Ct. at 1884-85, 20 L.Ed.2d at p. 911, emphasis added.)