Bethea v. Commonwealth

In Bethea v. Commonwealth, 245 Va. 416, 429 S.E.2d 211 (1993), the Supreme Court of Virginia held that when an officer establishes "'specific and articulable facts' which show that the officer was reasonably concerned for his safety during a valid automobile stop for a traffic violation and believed that the passenger might have had access to weapons with which to assault him," the ensuing detention is reasonable and permissible under the Fourth Amendment. Id. at 420, 429 S.E.2d at 211.