The Maryland court said ordering the passenger out of the car represented an unlawful seizure of the defendant's person. The court's decision followed a 1977 ruling by the U.S. Supreme Court in Pennsylvania versus Mimms that potential danger to a police officer during a traffic stop justified permitting the police officer to order the driver out of the vehicle. The issue in both court rulings is whether ordering the passenger rather than the driver out of the car makes a difference. The case is analyzed in terms of police officer safety when making traffic stops. It is concluded that danger to a police officer from a traffic stop is likely to be greater when there are passengers and that ordering the passenger out of the car constitutes a minimum intrusion. On the personal liberty side of the balance, however, the case for not ordering the passenger out of the car is stronger than that for the driver. 7 photographs