Hoskins v. Withers

Trooper’s request that driver sit in patrol car did not turn traffic stop into arrest where driver needed to look on his cell phone for proof of insurance, trooper needed to call dispatch from patrol car, and driver complied with trooper’s request; reasonable officer would not necessarily have known that trooper’s conduct during traffic stop—including taking driver’s second cell phone, pointing gun at him, applying handcuffs, conducting pat down, and putting him in patrol car—elevated investigative detention into arrest; driver reacted angrily to seizure of his phone, trooper could have reasonably believed that driver was reaching for gun when he placed his hands in or near his pockets, and that he needed to place driver in patrol car while he searched his vehicle, and law was not clearly established as to whether handcuffing would elevate detention into arrest.