State v. Sprague

¶ 1. The questions we address in this appeal are whether a reasonable person in defendant’s position would have felt free to refuse a state trooper’s request that he exit his vehicle, and whether a police officer may automatically order a driver to exit a vehicle following a routine traffic stop. We hold that the record evidence here did not support a finding that defendant voluntarily exited his vehicle. We further hold that a police officer must have a reasonable basis to believe that the officer’s safety, or the safety of others, is at risk or that a crime has been committed before…