State v. Kennedy
In State v. Kennedy, 107 Wn.2d 1, 11, 726 P.2d 445 (1986), the Court determined that, after a driver (Kennedy) was signaled to pull over, his movement in "leaning forward as if to put something under the seat" was "sufficient to give the officer an objective suspicion that Kennedy was secreting something under the front seat of the car," and we noted that the officer "had no way of knowing what Kennedy was hiding." Kennedy, 107 Wn.2d at 3, 11.
The Court observed that the officer "could have" frisked Kennedy (who was not under arrest but only under investigation) "had he suspected Kennedy might be armed." 107 Wn.2d at 11.