issue and if we have time i can touch very briefly on the second issue which is the second amendment issue with respect to the fourth amendment argument we need to alternative arguments first that the police conducted an unlawful arrest reasonable suspicion he was armed and dangerous at the time but respect to the arrest officer mcgrew immediately and cuffed darryl circles upon his exiting from the car again he was only a passenger in the car that was stopped for routine traffic infraction yeah after officer said that it was for safety measures but there are two important facts here that sort of refute that need to handcuff serials the first is that when the officer handcuffs ferals there were six officers on the scene for only three occupants in the car so there were two officers for every one person stopped and the officers greatly outnumber the occupants and second and maybe even more importantly the officer himself admitted that there was nothing particularly threatening or suspicious about searles at the time that he put him in handcuffs and case law has said that in order to use hand terry stop or a traffic stop on there has to be some sort of special circumstance in order to make that additional intrusion reasonable and none of those circumstances is present here as i said for safety measures that wasn't necessary because officers greatly outnumber the people stopped also this was just a routine traffic stop for failing to stop at a stop sign the driver didn't have a bisons this was not an officer investigating a violent crime not investigating a shooting or a robbery the officer had no reason to believe that anyone would be violent there was no reason for the officer to think that anyone would be a flight risk on everyone in the car it's also important to address the officers concerned about the area in which this traffic stop occurred the officer pointed to the fact that there had been a number of shootings in the area and that sort of elevated his suspicion but that's generally you know high crime area that doesn't necessarily give you a right to do to handcuff someone during a terry stop it's just  very broad you know there are shootings in the area over the past month none of those shootings was connected to anyone in the car just searle's of the driver the officers didn't have any reason to believe they were involved in gang activity  simply nothing at all connecting them to the shootings this was a traffic stop that was very routine so in fact officer mcgrew testified himself that with the shootings out there he just wanted to play everyone safe but that's not the sort of objective or reasonable mark of danger that's required to use handcuffs during a traffic stop if we look at a case like arnold or a case like johnson from this court just as he had some rights to protect themselves certainly and  what would i do well the case law says we have to have objective facts and the mere fact of a high crime area isn't an attractive fact it's high his belief that he needs to do is for safety measures to those particular people who are stopped he said so like these three or not i  no but i mean the officers were not investigating them pursuant to the shooting they weren't suspects in the shooting they didn't look like anyone remotely related to the shootings they didn't look like gang members there is nothing remotely connecting them to the shootings they just happen to be passing through this area but the officer believed it was a high crime area hope what the officers say regarding the behavior of the occupants of the car he said that they were doing nothing suspicious nothing threatening nothing illegal the officer said nothing about those people in the car themselves that would lead him to believe that he needed to use additional safety measures if handcuffing  terry and a lot of the other cases give them a whole lot of leeway to do that they can order the passengers out of the car they all the passengers are detained during the time of the stop but you have to have  and then he's handcuffed and immediately has to the other officer who immediately conducts the pat down and again the officer himself admits that he conducts the pat down and basically everybody we don't know if he's got a weapon or not and that's exactly the wrong standard under terry and you know forty years of law that you have to have a reasonable suspicion that this particular person who stopped is armed and dangerous and if the officers in you know could point to something if you could point to some furtive movements if you could point to some condition of gang activity if you look like a suspect in a crime those would be the type of things that would lead him to believe that he's armed and dangerous or the types of things that would allow him to battles on the officer said that he what he said is we want to play every once that we want to play everyone safe that he handcuffs or else for his safety he said that this was not a routine traffic stop because of the shootings in the area but the reason for the stop and everything that happened prior to the pat down was very routine it was blowing a stop sign driver didn't have a place everybody gets out of the car they're going to do their inventory that's all very routine type procedures that you would do for a traffic stop if the officers were able to point to something they would be able to justify that dish will intrusions change the law and that he might have the right steven inventory of the car if the car's being towed but even if the officer wanted to search the car there were six officers on the scene here for three people sorry couldn't figure out  all six there the by the time the officers ordered everyone out of the car all six were there so i think there was the first car who initiated the stop and then very shortly after two additional cars two officers each year came in just six officers on the scene who can you know conceivably control the scene and detain everyone without resorting to these very intrusive measures of handcuffs and that downs and if you're upholding what the officers did here was sort of wiping away you know what's left of the fourth amendment modren traffic stops saying that the officers can conduct pat downs on everybody and handcuff people without suspicion and there you know with very little restrictions on what they can do location we don't know if this block or this particular intersection where he was stopped was the high crime area  right but which is that area mean is that area i mean that entire neighborhood is that area i mean the entire block if perhaps yet so we're allowing the you know the police already have a lot of discretion and what not and to allow them to say you know in this area as a basis for handcuffs as you know was examined an issue on the high crime area there is there is a little bit i mean and certainly there's cross examination on the fact that searle's was not or anyone in this car was not associated with or could be connected with any part of that crime and that's what's most important is that they were not related to that crime richardson on behalf of the people of the state of illinois the actions of the officers in this case did not appear in the fourth amendment first this was a valid traffic stop where the car failed to stop  sign next when the java cannot produce a valid driver's license the authors were required to take him in and everyone has to get out of the car the officers were aware that there was shootings going on every day in this area they glass recovered out of this exact street she it's where this car was stopped there are three men in the car and there was a gang war going on so we are not talking about a just a high crime area there were a very particular  now being arrested and everyone has to get out of the car they couldn't allow the jive to continue driving without his license and then i'll search rollaway are there only four officers at the scene if we look at the record page the forty three there were four officer no yana is there any indication that any of the occupants of that car was associated with the games now you are now was there any indication of the last recovery where a car in within the last week to a much and also someone i testified that these shootings right occurring every day so is there any indication that shooting had occurred on the day of the stop no yana however office  reconcile and i'll search for an objective standard with the office testimony that we frisk everybody right on our way counsel failed to mention them which is an implied in fact that they actually i think grammar school kids that wearing cellphones and where there is an articulable suspicion we will permit the officer to frisk to secure his safety his or her safety but the handcuffing according to johnson is a step too far here a chronological order as i recall correct me if i'm wrong the occupants of the car who are doing absolutely nothing according to the office testimony and again correct me if i'm wrong are ordered out of the car and immediately handcuff about a very narrow area and a very narrow time frankly we're not talking about it you know i kind of a ritual yes where shootings are going on every day or a handcuffing does not necessarily suspicion in addition to this other reason reasonable suspicion to perform this task that it was actually the pat down that way it's the recovery of this this ball shows them plain sight and would have been observation regardless of the handcuffing there's no caus you thank you gunners first i just want to clarify the record a little bit there were in fact six officers on the scene if you read the group's testimony he names all six officers salonen the crew kook hadn't only highlights the and reasonableness of what happened here and if the officers didn't wait or didn't look for signs of suspicion or reasons that they should be concerned about their safety they immediately went to handcuffin doing the pat down with respect to the narrow area and time frame the counsel described in describing this is a high crime area unfortunately you know chicago has a lot of shootings and so to allow the fact of recent shootings to give you reasonable suspicion or reason to handcuffs with you know step or dies everyone who goes through certain parts of the city and happens to get stopped for blowing a stop sign or doing any number of traffic infractions it does virtually nothing to give at jacked of in effect a factors to what the officers are permitted to do and then finally with respect to the boat but it's difficult to believe that this bolt was really a factor in what happened here in causing the pat down where the officer himself described the bulge in the most innocuous terms he described it as a  slight and nothing major it was only two or three inches it was not characteristic of a gun and there is no evidence that it was shaped like a gun it had  has objective or reasonable facts to support his belief that the boat is the weapon and so if he knows that this defendant you know might be armed because he's investigating a shooting if he's you know thinks that it has the outline of a weapon those are the kinds of objective factors that given a reason but the officers a reason to do what they say a reason to do what to do the pat down ok if he has those objective reasonable factors and then the officer certainly can do that have down to protect the safety but the case has been very clear that you need more it would it would they give them all sure reason to handcuff the occupant of a car involved in a traffic infraction probably maybe probably not oh it's certainly one factor that the courts can look at to determine whether the handcuffing was reasonable if you have reason to think that he's violent are going to use force against the officer that sort of thing that's