What is a Terry stop or pat down?
Two separate things get bundled under one name, and they require separate justifications.
The stop. An officer may briefly detain a person where there's reasonable suspicion — specific, articulable facts suggesting criminal activity. Less than probable cause, more than a hunch.
The frisk. A pat down of outer clothing requires an *additional* justification: reason to believe the person is armed and dangerous. A lawful stop does not automatically authorize a frisk.
The frisk is also limited in scope. It's a pat of the outer clothing for weapons, not an exploratory search. An officer who manipulates an object to determine what it is has exceeded it — though contraband whose identity is immediately apparent by touch can be seized.
Most challenges here attack one of the two justifications independently, and the second is frequently weaker than the first.
They need a reason to stop you and a separate reason to pat you down. ---
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