Terry Searches of Motor Vehicles”. PATC 2014: n. pag. Print.Abstract
n 1983, the United States Supreme Court, in Michigan v. Long [i], held that officers may conduct a search of the passenger compartment of a motor vehicle, limited to areas that could conceal a weapon, when there are specific, articulable facts that provide the officer with a reasonable belief that an occupant of the vehicle is dangerous and may gain immediate control of weapons. On March 19, 2014, the Court of Appeals of Georgia decided the State v. Snead [ii], which serves as an excellent example of an application of the rule from Michigan v. Long.
Question: Can a police officer remove a firearm from a vehicle without articulation that the person poses a danger? Answer: Some jurisdictions (like Georgia) require additional articulation that the suspect is not only armed, but dangerous as well.