of Terry. Since the officers were allowed to ask Mimms to step out of the car, this set a precedent that officers could now ask citizens to perform actions through warrantless intrusion. Search A 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 what is necessary to discover weapons, and must be based on a reasonable suspicion the individual may be armed. However, pursuant to the plain feel doctrine (similar to the plain view doctrine), police may seize contraband discovered in the course of a frisk, but only if the contraband's identity is immediately apparent. The Supreme Court has placed very liberal requirements on what is "immediately apparent" regarding contraband. For example, in conducting a pat-down search, an officer feels a hard pack of cigarettes; the officer removes the pack and examines the inside, discovering drugs. He can be allowed to do this because he has prior knowledge, based on experience, that a small switchblade or tiny gun could be hidden in such a box. 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 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. Consensual search Based on the Supreme Court decision in Schneckloth v. Bustamonte (1972), a person waives Fourth Amendment protections when giving voluntary consent to a search. Police are not required to inform a person of their right to decline the search. Justice Marshall, in his dissent in the case, said 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". Several cities and states require police to inform citizens of their right to deny a search. Traffic stops For practical purposes, a traffic stop is essentially the same as a Terry stop; for the duration of a stop, driver and passengers are "seized" within the meaning of the Fourth Amendment. The Supreme Court has held that drivers and passengers may be ordered out of