In Sikes v. State, 981 S.W.2d 490 (Tex. App. -- Austin 1998, no pet.), a university campus police officer saw an individual put his hand through the plastic lining window of a jeep, then remove it, return to a waiting vehicle, and drive away. 981 S.W.2d at 491. Thinking he had just observed a burglary of a vehicle, the officer stopped the car. The driver of the car gave permission to search the car, so the driver and the defendant were ordered out of the vehicle. It was midafternoon, and the defendant was entirely cooperative, did not appear dangerous, and was being observed by a second officer during the vehicle search. Despite these innocuous conditions, the officer patted the defendant down for weapons, later testifying "I do a pat-down search whenever we search a vehicle to make sure that they [do] not pull out something while we're searching the vehicle." The court of appeals held that there were no specific, articulable facts to support any concern for the officer's safety. Id. at 494. The only justification for the frisk was the officer's routine, and the court held that "constitutional protections against unreasonable searches cannot be whittled away by police regulations or standard operating procedure." Ibid.