State v. Riley (1999)
In State v. Riley, 196 Ariz. 40, 992 P.2d 1135 (App. 1999), the Court found that a police officer had reasonable suspicion to continue his investigation after the initial stop following a high-speed chase. 196 Ariz. 40, PP11, 15, 992 P.2d at 1139-40.
There, the driver was "unable to provide the vehicle owner's name or phone number, claimed not to know his passenger's last name, possessed questionable identification, was sweating despite the winter temperature, and claimed to be going home, but was headed in the opposite direction from the address on his temporary license." Id. P15.
The officer asked the driver to step out of the vehicle and, when he ignored instructions to keep his hands out of his pockets, "patted him down" and found two large bundles of cash in bank wrappers. Id. P12.
The officer requested Riley, a passenger in the vehicle, to step out and asked whether he was carrying anything that would hurt the officer. Id. P13.
When Riley reached for his waistband, the officer pushed him against the car, conducted a pat-down search, and found two handguns. Id.
Under these circumstances, we concluded the officer's reasonable concern for his safety justified the pat-down searches and the trial court did not err in denying the motion to suppress the evidence. Id. P16.