What is the holding in Pennsylvania v. Mimms?

Pennsylvania v. Mimms

The controlling Supreme Court decision is Pennsylvania v. Mimms, 434 U.S. 106 (1977). It holds that, during a lawful traffic stop, an officer may order the driver out of the vehicle as a matter of course without individualized suspicion, because the minimal additional intrusion is outweighed by legitimate officer-safety concerns.[1][2]

Key holding

“The order to get out of the car, issued after the respondent was lawfully detained, was reasonable, and thus permissible under the Fourth Amendment.”[1]

The Court also held that once the officer observed a bulge under Mimms’s jacket, the frisk was justified under Terry v. Ohio, 392 U.S. 1 (1968). [1][2]

Citation

Pennsylvania v. Mimms, 434 U.S. 106 (1977)

Bottom line

If you want the case for a Fourth Amendment traffic-stop proposition, this is the leading authority: officers may, during a lawful stop, direct the driver to exit the vehicle even without a separate justification.[1][2]