In State v. Otero, 245 N.J. Super. 83, 584 A.2d 260 (App.Div.1990), the officer's initial stop of defendant's automobile was justified since he had an articulable and reasonable suspicion that defendant was involved in a nearby house burglary. After the stop, the officer requested that the defendant place his hands on the dashboard of the car. The defendant, however, refused to comply, and this resistance provided the officer with a reasonable suspicion that the defendant may have been armed. The court held that the subsequent frisk was valid since "the original investigatory encounter thus escalated to a 'stop and frisk' by reason of the actions of the defendant. . . ." Id. at 92, 584 A.2d 260.