State v. Parker

In State v. Parker, 139 Wn.2d 486, 987 P.2d 73 (1999), the lead opinion of the Court recognized that the arrest of a vehicle occupant supplied an additional factor that an officer could consider when controlling the scene of a vehicle stop: "The circumstance of an arrest falls squarely within the rule of State v. Mendez, 137 Wn.2d 208, 970 P.2d 722 (1999).Thus, a vehicle stop and arrest in and of itself provides officers an objective basis to ensure their safety by "controlling the scene," including ordering passengers in or out of the vehicle as necessary." (Id. at 502.)