A police officer may order a passenger who exits a vehicle during a traffic stop back into the vehicle in the interest of officer safety. Noting the intrusions on a passenger’s liberty that occur by virtue of a traffic stop, and the fact that a passenger may be ordered out of a vehicle for officer safety reasons, the court found that the minimal additional intrusion on a passenger’s liberty when he is ordered to remain in a car did not offend the Fourth Amendment. The need for officers to exercise control over individuals encountered during a traffic stop outweighs the marginal intrusion on the passenger’s liberty interest.