identify himself. Dissenting opinion of Justice Douglas Justice William O. Douglas strongly disagreed with permitting a stop and search absent probable cause: We hold today that the police have greater authority to make a 'seizure' and conduct a 'search' than a judge has to authorize such action. We have said precisely the opposite over and over again. To give the police greater power than a magistrate is to take a long step down the totalitarian path. Perhaps such a step is desirable to cope with modern forms of lawlessness. But if it is taken, it should be the deliberate choice of the people through a constitutional amendment. Later criticism Terry was criticized in 1997 for inaccurately summarizing the facts of the case itself. It was also criticized for "fail[ing] to strike a meaningful Fourth Amendment balance between effective law enforcement and individual freedom." Subsequent jurisprudence Terry set precedent for a wide assortment of Fourth Amendment cases. The cases range from street stop-and-frisks to traffic stops in which pat-down searches could be conducted on the driver or passengers. In Michigan v. Long, the Supreme Court ruled that car compartments could be constitutionally searched if an officer had reasonable suspicion that the suspect is armed and dangerous. Thus the compartments are viewed as an extension of the suspect's person. This is known as "frisking the lunge area," as an officer may protect himself by searching any areas from which the suspect could grab a weapon. The Terry doctrine was markedly extended in the 2004 case of Hiibel v. Sixth Judicial District Court of Nevada, , in which the Supreme Court held that a state law requiring the suspect to identify himself during a Terry stop did not necessarily violate the Fourth Amendment prohibitions of unreasonable searches and seizures or the Fifth Amendment privilege against self-incrimination (although potentially could if the citizen in question reasonably believed that such identification could be used to incriminate). The Court did not legalize this process in all states but instead left it up to the states to decide whether they would pass such laws. So far 24 states have passed such laws. The Court most recently cited Terry v. Ohio in Arizona v. Johnson. In that 2009 case, the Court ruled 9–0 in favor of further expanding Terry, granting police the ability to frisk an individual in a stopped vehicle if there is reasonable suspicion to believe