State v. Jewett
In State v. Jewett, 148 Vt. 324, 327, 532 A.2d 958, 959 (1986), the defendant claimed that the police had violated his rights under Chapter I, Article 11 of the Vermont Constitution by ordering him out of his vehicle after an officer stopped him for erratic driving and observed signs of intoxication.
While recognizing the Fourth Amendment rule announced in Mimms, we held that an order to exit one's vehicle is a "further 'seizure' within the meaning of Article Eleven." Id. at 330, 532 A.2d at 961.
The Court further held that such a seizure was "not, however, completely outside the realm of legitimate law enforcement conduct where the suspected criminal activity is DUI." Id.