In United States v. Baker, the defendant argued that being required by a police officer to lift his shirt tail slightly so that the officer could identify the cause of a suspicious-looking bulge constituted an unlawful search of his person. The U.S. Fourth Circuit Court of Appeals held that the district court was in error in concluding that the officer lacked a proper basis to conduct a protective search. Because of the hazards involved in a roadside encounter with a suspect, a law enforcement officer may conduct a protective search aimed at uncovering concealed weapons after making a proper traffic stop if the officer "possesses a reasonable belief based on 'specific and articulable facts which, taken together with the rational inferences from those facts, reasonably warrant' the officer in believing that the suspect is dangerous." Based upon an examination of the video that showed the techniques of South Carolina Highway Patrol officer Mark Coates in making the vehicle stop that resulted in his death, this section of the instruction focuses on lessons to be learned about the proper approach to a stopped vehicle and the positioning of the officer when conversing with the driver. The suggested techniques are designed to give the officer the advantage in case a suspect should attempt a physical assault or a firearm attack.