nature of the holdings in mimms and miller police vs peace officer in carefully reviewing these cases i cannot find support for the language i used several years ago so i ve revised it to strictly reflect what the court actually said although the court did not expressly require that a peace officer cite particularized concern for his safety they did not expressly say that it was unnecessary either the clarification of federal law is also important because the supreme court empowered under article iii of the us constitution cannot really grant authority to a peace officer rather they are limited to interpretation of laws and review for conformance with the constitution as they make quite clear in the citation from mimms i ve added a tag to the assertion that state law may not allow drivers or passengers to be ordered to exit the vehicle though this assertion may be correct it s pretty sweeping and needs support it may be particularly significant in light of the death of sandra bland many pundits have insisted that ms bland s failure to exit her car when so ordered provided cause for arrest usually citing mimms and miller and perhaps texas transportation code the supreme court holdings were of course limited to the fourth amendment and did not and could not consider whether refusal to exit a vehicle after being so ordered violated state law unless the commerce clause of article i is somehow involved and this seems unlikely that would be a matter for state legislators to regulate and state courts to interpret some states well may have done so however i have been unable to find anything close to dispositive and have not seen anyone else do so i am not going to make a project of running this down but if someone else can provide this information it would seem a great addition hopefully any such reference would cite real decisional law that is unambiguous to the average reader rather than a mere assertion by a third party if the third party cannot cite authority that party s assertion is suspect police vs peace officer i do not understand the suggestion that peace officer or law enforcement officer is strictly the proper term needs support i think the linked wp article makes it quite clear that either of these terms which refer to a superset of police officer are the strictly correct usage i used police simply because in some other articles other editors usually ip kept changing it to police officer and the bickering seemed a poor use of time and i reasoned that if the supreme court can use police correctly or otherwise we cannot be faulted for doing so here whoever added that tag did not give a reason absent some good reason to keep it or perhaps a suggested rewording of the note i m inclined to remove the tag