Defendant’s stop for a taillight being out was cause for the stop, defendant’s inability answer basic questions about what he was doing and where he was going in a high crime area, his criminal record, and his generally matching the description of a robber became reasonable suspicion. A protective weapons search under Michigan v. Long is an exception to Gant. United States v. Lewis, 2012 U.S. App. LEXIS 3241 (4th Cir. February 16, 2012) (unpublished)*:
[T]the officer reasonably believed that Lewis could be armed and dangerous. Moreover, Lewis' lack of restraint and close proximity to the driver's side door permit the conclusion that Lewis could access any weapons within the vehicle. See Long, 463 U.S. at 1051-52; United States v. Elston, 479 F.3d 314, 320 (4th Cir. 2007).
... [T]he limited restraint placed on Lewis prior to the search did not amount to a formal arrest that would trigger Gant's protection.