Defendant ignored 7-10 shouts to keep his hands up and get out of the car, and he reached down into the back seat. Officers opened the door and pulled him. Then he was seized, and it was reasonable to pull him out. Checking under the seat, drugs were found. The protective search under the seat was reasonable. Hill v. Commonwealth, 2019 Va. LEXIS 104 (Aug. 30, 2019).
There was reasonable suspicion for continuing defendant’s stop because he was driving a car with a single key in the ignition, he said he borrowed the car from a friend that he couldn’t name, he had a car with PA plates but he was driving from his home in NY to PA. Commonwealth v. Benitez, 2019 PA Super 268 (Sept. 3, 2019).*