Phillip George O’hara, Appellant v. the State of Texas

Summary

The Court held that a pat‑down search is valid when specific, articulable facts justify a reasonable officer’s belief that the suspect may be armed, regardless of whether the officer expresses fear, and reversed the appellate court’s decision. The Court also rejected the notion that routine alone justifies a frisk, and remanded for consideration of the appellant’s second point of error. Justice Mansfield’s concurring opinion agreed with the majority’s reasoning.