The Court held that officers could order passengers out a car during a traffic stop, extending Pennsylvania v. Mimms.

During Wilson's trial, the Circuit Court of Baltimore County suppressed the crack cocaine as fruit of the poisonous tree.

The Court ruled that Mimms applies to passengers due to similar public safety concerns.

He argued that the majority decision relied on scant evidence and misleading statistics to justify the intrusion of a potentially innocent person's liberty.

Finally, Stevens believes that as long as there is no reasonable suspicion against them, a passenger should be able to decide whether to stay in a vehicle instead of having to risk exposure to bad weather or prying eyes.