A fleeting targets search may be made at any time and any place where you have lawful access and PC.
After Apr. 19, officers and agencies could incur liability for vehicle searches incident to arrest that do not fall within the Gant guidelines.
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.
In your search warrant affidavits, your reports, and your testimony you have to lay out the basis of your suspicions and justify every detention, arrest, search, seizure, entry, and use of force.
On average, 60,000 officers are assaulted on the job every year. That's an average of 164 per day. The risk level you face on the job makes it important not only to resist complacency and to follow prudent tactics, but also to understand how to ensure that your interactions with suspects are constitutionally justifiable, so that you are never forced to choose between being safe and being sued.
In the 2007 decision in Brendlin v. California, the U.S. Supreme Court added yet another to a series of Fourth Amendment opinions on the subject of vehicle searches and seizures involving passengers, rather than drivers.