In People v. Key (81 A.D.2d 805 [2d Dept. 1981], appeal dismissed 54 N.Y.2d 813), for instance, police officers observed defendant slumped over the wheel of a lawfully parked car in Manhattan. The key was in the ignition but the engine was not running. The officers approached the car and knocked on the window, awakening defendant. When defendant rolled down the window, the officers observed indicia of intoxications, including slurred speech. Defendant was then ordered to exit the car and produce his license and registration. As defendant alighted from the car, a loaded gun fell from out of the car onto the street. He was charged with criminal possession of that weapon. The trial court in Key suppressed the gun, ruling that the officers were not justified in asking defendant to exit the car because there was no basis to believe that he had violated the law. The Second Department reversed. It held that, even though there was no suspicion of criminal activity, the police conduct was justified by public safety concerns. "In requesting defendant to leave the car and exhibit his license and registration," the court in Key stated, "the officers were taking reasonable precautions to forestall the operation of the vehicle by one who may have been drinking" (81 A.D.2d at 806). "The intrusion was, at most, de minimus, and not violative of defendant's Fourth Amendment rights."