On February 19, 1997, the United States Supreme Court handed down its decision in Maryland v. Wilson, and put an end to twenty years of speculation regarding a police officer's authority to order a passenger out of a lawfully stopped automobile. In finding that such an order does not violate a passenger's Fourth Amendment privacy interests, the Supreme Court reversed Maryland's Court of Special Appeals and sided with the majority of states that have considered this narrow issue. The Court's decision provides important insight into the current state of Fourth Amendment jurisprudence and the Supreme Court's increasing willingness to sacrifice individual liberties, particularly in the automobile context, to further law enforcement objectives.
Liberty From Officials by Grace: The Fourth Amendment's Application to Automobile Passengers in Maryland v. Wilson,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol31/iss2/8