In Terry v. Ohio, 392 U.S. 1 (1968), the United States Supreme Court established the analytical framework for evaluating the reasonableness of a search or seizure by the police under the Fourth Amendment. In Terry, the Court applied the balancing test to an on-the-street encounter between a police officer and three men the officer suspected were planning a robbery. After observing the men engage in conduct the officer believed amounted to "casing" a store in preparation for a robbery, the officer detained the men for questioning and frisked them for weapons. Id. at 6-7. A gun recovered from the petitioner Terry was used to prosecute him for carrying a concealed weapon. Id. at 8. While recognizing that an investigative stop and frisk constituted a severe, though brief, intrusion on Terry's personal security, the Court held that when balanced against the governmental interests, the police officer's conduct was reasonable and therefore permissible under the Fourth Amendment. Id. at 24-25, 30-31. The Court first concluded that the governmental interest in effective crime prevention and detection justified the officer's detention of Terry and his companions for further questioning. Id. at 22-23. In light of the men's behavior, "it would have been poor police work indeed" for the officer to have failed to investigate further. Id. at 23. The officer's frisk of Terry for weapons was additionally justified by the governmental interest in allowing a police officer to take "steps to assure himself that the person with whom he is dealing is not armed with a weapon that could unexpectedly and fatally be used against" the officer. Id. The Court determined that it would be "unreasonable to require that police officers take unnecessary risks in the performance of their duties" or to deny an officer "the power to take necessary measures to determine whether the person is in fact carrying a weapon and to neutralize the threat of physical harm." Id. at 23-24. The Court concluded: Our evaluation of the proper balance that has to be struck in this type of case leads us to conclude that there must be a narrowly drawn authority to permit a reasonable search for weapons for the protection of the police officer, where he has reason to believe that he is dealing with an armed and dangerous individual, regardless of whether he has probable cause to arrest the individual for a crime. The officer need not be absolutely certain that the individual is armed; the issue is whether a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger. Id. at 27. The Court held that under the particular circumstances of the case, the frisk of Terry had been a reasonable search under the Fourth Amendment and that the gun recovered from him was properly admitted in evidence. Id. at 30-31. Each case of this sort will, of course, have to be decided on its own facts. We merely hold today that 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 30. The United States Supreme Court made it clear an officer may only detain a person if the officer first has observed "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. Such a search is a reasonable search under the Fourth Amendment, and any weapons seized may properly be introduced in evidence against the person from whom they were taken." (Terry v. Ohio, supra, at pp. 30-31.) The officer in Terry v. Ohio was able to give reasonable articulable facts justifying his seizure and patdown based on the suspects' actions that reasonably showed they were checking businesses for a daylight robbery. (Terry v. Ohio, supra, 392 U.S. at p. 28.) The United States Supreme Court determined that "a police officer may in appropriate circumstances and in an appropriate manner approach a person for purposes of investigating possible criminal behavior even though there is no probable cause to make an arrest." However, for the propriety of a brief investigatory stop pursuant to Terry, the police officer involved "must be able to point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion." Id. at 21. In Terry, the United States Supreme Court held that police may briefly stop and detain an individual, without an arrest warrant or probable cause for an arrest, in order to investigate a reasonable suspicion of criminal activity. Id. at 21. Under Terry, if a law enforcement officer develops a reasonable suspicion and detains the individual to investigate, the officer may conduct a protective search to determine if the individual has any concealed weapons. Id. at 27. Further, while conducting the Terry search, "if a police officer lawfully pats down a suspect's outer clothing and feels an object whose contour or mass makes its identity immediately apparent, such as drugs, there has been no invasion of the suspect's privacy beyond that already authorized by the officer's search for weapons." Minnesota v. Dickerson (1998), 508 U.S. 366, 375, 113 S. Ct. 2130, 124 L. Ed. 2d 334. In Terry v. Ohio, the United States Supreme Court held that a police officer may stop and investigate unusual behavior, even without probable cause to arrest, when he reasonably concludes that the individual is engaged in criminal activity. In assessing that conclusion, the officer must be able to point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion. Furthermore, the standard against which the facts are judged must be an objective one: "Would the facts available to the officer at the moment of the seizure or the search 'warrant a man of reasonable caution in the belief' that the action taken was appropriate?" Id. at 21-22. The United States Supreme Court created a limited exception in the context of brief investigatory police stops to the standard requirement that police seizures be supported by probable cause. According to the standards set forth in Terry, a police officer may briefly detain and question individuals to investigate possible criminal behavior if "specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion" are present. Terry, 392 U.S. at 21, 20 L. Ed. 2d at 906, 88 S. Ct. at 1880. In Terry v. Ohio, the Supreme Court explained: There is the more immediate interest of the police officer in taking steps to assure himself that the person with whom he is dealing is not armed with a weapon that could unexpectedly and fatally be used against him. Certainly it would be unreasonable to require that police officers take unnecessary risks in the performance of their duties. American criminals have a long tradition of armed violence, and every year in this country many law enforcement officers are killed in the line of duty, and thousands more are wounded. Virtually all of these deaths and a substantial portion of the injuries are inflicted with guns and knives. In view of these facts, we cannot blind ourselves to the need for law enforcement officers to protect themselves and other prospective victims of violence in situations where they may lack probable cause for an arrest. When an officer is justified in believing that the individual whose suspicious behavior he is investigating at close range is armed and presently dangerous to the officer or others, it would appear to be clearly unreasonable to deny the officer the power to take necessary measures to determine whether the person is in fact carrying a weapon and to neutralize the threat of physical harm. Terry, 392 U.S. at 23-24. A search for weapons in the absence of probable cause to arrest, however, must, like any other search, be strictly circumscribed by the exigencies which justify its initiation. Thus, it must be limited to that which might be used to harm the officer or others nearby, and may realistically be characterized as something less than a "full" search, even though it remains a serious intrusion. Terry, 392 U.S. at 25-26. The United States Supreme Court held that a police officer may briefly detain a suspect for investigative purposes based on a reasonable suspicion of criminal activity. ( Id. at pp. 30-31.) Where, in the course of a lawful detention, a police officer's observations lead the officer "reasonably to conclude in light of his experience . . . that the persons with whom he is dealing may be armed and presently dangerous" ( id. at p. 30), the officer may conduct a protective "carefully limited search of the outer clothing of such persons in an attempt to discover weapons . . . ." (Ibid.) "The officer need not be absolutely certain that the individual is armed; the issue is whether a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger. " ( Id. at p. 27.) In Terry v. Ohio, the United States Supreme Court held that a police officer may briefly detain a suspect for investigative purposes based on a reasonable suspicion of criminal activity. ( Id. at pp. 30-31.) Where, in the course of a lawful detention, a police officer's observations lead the officer "reasonably to conclude in light of his experience . . . that the persons with whom he is dealing may be armed and presently dangerous" ( id. at p. 30), the officer may conduct a protective "carefully limited search of the outer clothing of such persons in an attempt to discover weapons . . . ." (Ibid.) "The officer need not be absolutely certain that the individual is armed; the issue is whether a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger." ( Id. at p. 27.) The central inquiry under the Fourth Amendment is the reasonableness under all the circumstances of the particular governmental invasion. ( Id. at p. 19.) "There is 'no ready test for determining reasonableness other than by balancing the need to search or seize against the invasion which the search or seizure entails. '" ( Id. at p. 21.) "In making that assessment it is imperative that the facts be judged against an objective standard: would the facts available to the officer at the moment of the seizure or search 'warrant a person of reasonable caution in the belief' that the action taken was appropriate?" ( Id. at pp. 21-22.) The Supreme Court recognized the reasonableness of minimally intrusive invasions of a person's privacy interest when justified by a reasonable concern for officer protection. The court upheld the constitutionality of a pat down search of a detained individual's outer clothing where there is an articulable basis for concern that the individual may be carrying a concealed weapon that could pose a threat to the officer's safety. (Terry, supra, 392 U.S. at p. 27-30.) The court acknowledged that a pat down search may result in an annoying, frightening, or perhaps humiliating experience for many individuals, but upheld such a brief invasion as a necessary practice reasonably limited to discover instruments of assault. (Id. at pp. 25-26). The Court concluded officers may undertake a properly limited search for weapons if "a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger." (Ibid.) Officers need not be certain the suspect is armed. However, they must have specific and articulable facts to support their suspicion that the suspect is armed and dangerous. (Terry, supra, 392 U.S. at p. 30.)