The Institute for Justice summarized a 10th Circuit case regarding a car involved in an immediately prior weapons case, its driver, and a weapon thusly:
Aurora, CO, police run tags on car with broken tail light, discover the car was seized three weeks earlier in weapons-possession case and a man (a known gang member) associated with the car was arrested. They pull it over; the man is in it; they frisk him and find a gun. He’s charged with being a felon in possession. Suppress the evidence? No need, says the 10th Circuit. Though he was calm and compliant, officers were justified in patting him down to ensure their safety.
Dissent: The gov’t is going to use this decision to justify frisks in a much broader variety of circumstances than the ones here.
The dissenting judge may well be right, but he’s speculating only. Treat those speculatedly future cases one by each, as the unique cases they will be, and rule in accordance with the facts of those cases, not the facts of this case.