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Although it's common to see the term "stop and frisk," it's possible that there might be justification for a stop, but not for a frisk.
Unfortunately, Officer Erfle will not be the last law enforcement officer who will fall victim to a bad guy carrying a concealed firearm. The reason is simple; unless you have cause to search, you really can't tell who is packing and who isn't.
Every year officers are disarmed and murdered with their own weapons. It only makes sense to always carry while off duty and to always carry a back-up weapon while on duty.