Aguilar v. State

In Aguilar v. State, 88 Md. App. 276, 287, 594 A.2d 1167 (1991), the Court summarized additional limitations on a police officer's right to extend a search beyond the initial pat-down: If an officer pats a person's clothing and feels only a soft object, a further search is not allowed. Anderson v. State, 78 Md. App. 471, 487, 553 A.2d 1296 (1989). Where the patdown discloses a hard object, but the officer can determine from the shape of the object that the object is not a weapon, a further search is not allowed. Alfred v. State, 61 Md. App. 647, 487 A.2d 1228 (1985). . . . Finally, we pointed out in Anderson v. State, supra, that an officer may not, without first conducting a pat-down, reach into a suspect's pocket and remove hard objects simply because the officer has a reasonable basis to believe that the suspect is armed. (88 Md. App. at 285-86.)