The Court of Appeals decided in People v. Howell (49 NY2d 778, 403 N.E.2d 182, 426 N.Y.S.2d 477 [1980]) that the circumstances fell within the traffic infraction exception articulated in Troiano (see Howell at 780). The defendant was pulled over for erratic driving, and the trial court concluded that a frisk of the defendant was inevitable and proper because reckless driving was a misdemeanor. The Court of Appeals held that this conclusion was error: "An arrest in a situation such as was presented in this case was neither called for nor the preferred procedure" (People v. Howell at 779; see also People v. Adams, 32 NY2d 451, 454-55, 299 N.E.2d 653, 346 N.Y.S.2d 229 [1973]).