Editing Terry stop (section)

===Search===

A [[frisking|frisk]], also known as a pat-down, of the surface of a suspect's garments is permitted during a ''Terry'' stop but must be limited to actions necessary to discover weapons and must be based on a reasonable suspicion the individual may be armed.<ref>{{cite web|last1=Argiriou|first1=Steven|title=Terry Frisk Update|url=https://www.fletc.gov/sites/default/files/imported_files/training/programs/legal-division/downloads-articles-and-faqs/research-by-subject/4th-amendment/terryfriskupdate.pdf|website=Federal Law Enforcement Training Center|access-date=13 November 2018}}</ref> However, pursuant to the plain-feel doctrine (similar to the [[plain view doctrine|plain-view doctrine]]), police may seize [[contraband]] discovered in the course of a frisk, but only if the type of contraband is immediately apparent.<ref name=samaha/>

The Supreme Court has placed very liberal requirements on what is "immediately apparent" regarding contraband. In an example provided by the [[Federal Law Enforcement Training Centers]], an officer feels a hard pack of cigarettes while frisking a suspect and inspects the pack, discovering drugs inside. The officer is legally permitted to open the pack because he has prior knowledge, based on experience, that a small switchblade or tiny gun could be hidden in such a box.<ref>{{cite report |title=Terry Frisk Update |url=https://www.fletc.gov/sites/default/files/imported_files/training/programs/legal-division/downloads-articles-and-faqs/research-by-subject/4th-amendment/terryfriskupdate.pdf |publisher=Federal Law Enforcement Training Centers}}</ref>

Subsequent court cases have expanded the definition of what constitutes a frisk and what is considered as [[admissible evidence]]. In ''[[Michigan v. Long]]'', ''Terry'' stops were extended to searching the inside of a car passenger compartment if police have reasonable suspicion that an occupant may have access to a weapon there. In ''[[Minnesota v. Dickerson]]'', the court ruled that "immediately recognized" contraband discovered during a ''Terry'' stop is also a lawful seizure.<ref name=Gandy-2016>{{cite web |last1=Gandy |first1=Imani |title=Boom! Lawyered: Stop-and-Frisk Edition |url=https://rewire.news/ablc/2016/10/07/boom-lawyered-stop-frisk-edition/ |website=Rewire.News |access-date=13 November 2018 |date=7 October 2016}}</ref>

==== Consensual search ====
Based on the Supreme Court decision in ''[[Schneckloth v. Bustamonte]]'' (1972), a person waives Fourth Amendment protections when voluntarily [[consent search|consenting to a search]]. Police are not required to inform a person of his or her right to decline the search. Justice Marshall, in his dissent, wrote that it is a "curious result that one can choose to relinquish a constitutional right—the right to be free from unreasonable searches—without knowing that he has the alternative of refusing to accede to a police request."<ref>{{cite journal |last=Loewy |first=Arnold H. |date=2010 |title=Knowing 'Consent' Means 'Knowing Consent' – The Underappreciated Wisdom of Justice Marshall's Schneckloth v. Bustamonte Dissent |url=https://olemiss.edu/depts/ncjrl/pdf/2009%20Loewy.pdf |journal=Mississippi Law Journal |volume=79 |issue=1}}</ref><ref>{{cite journal |last=Burke |first=Alafair S.  |date=2016 |title=Consent Searches and Fourth Amendment Reasonableness |url=https://scholarship.law.ufl.edu/cgi/viewcontent.cgi?article=1227&context=flr |journal=Florida Law Review |volume=67 |issue=2}}</ref> Several cities and states require police to inform citizens of their right to deny a search.