In State v. Triplett (Wis.Ct.App. 2005) 707 N.W.2d 881, the officer had difficulty searching the defendant's waist area due to the defendant's large frame and the heavy clothing he was wearing. The officer thought he could get a better patdown if he first loosened any weapons that might be hidden in the waistband, so he tugged on the defendant's belt loops and gave the waistband a few shakes. As he shook, a clear plastic bag containing cocaine base dropped from the bottom of the defendant's right pants leg. (Id. at p. 882.) Upholding the scope of the patsearch, the court observed that the Supreme Court in Terry v. Ohio (1968)had refused to adopt any bright-line rule for what constitutes a reasonable search for weapons, and recognized that the proper scope of such a search depends on the unique circumstances in each individual case. (Id. at pp. 883-884)