In the case of Arizona v. Lemon Montrea Johnson, 2008, the U.S Supreme Court examined whether police officers had violated Fourth Amendment rights during a stop-and-frisk procedure. The defendant, Lemon Montrea Johnson was stopped by an officer for driving with a suspended license plate and subsequently frisked due to his suspicious behavior. During this pat-down search, the officer discovered a gun and marijuana in his possession which led to charges being filed against him. However, Johnson argued that these items should not be admissible as evidence because they were obtained through an unlawful search and seizure process since there was no reasonable suspicion of criminal activity beyond the traffic violation when he was initially stopped by law enforcement officials. The court ruled in favor of Arizona stating that while it is true that traffic violations alone do not justify a pat-down search under normal circumstances; however if during such stops officers observe additional suspicious behaviors or indications suggesting potential danger or criminal activity then they are justified in conducting further searches for their own safety and others'. In this particular case, factors like Mr.Johnson's nervousness along with other observations made by officers provided enough grounds for them to conduct a frisk.

In the dissenting opinion for Arizona v. Johnson, Justice Ginsburg argued that the majority's decision expanded police power too far and threatened individual privacy rights. She contended that a pat-down search should only be permissible if an officer has reasonable suspicion to believe a person is armed and dangerous, not merely because they are lawfully detained during a traffic stop. The justice believed there was insufficient evidence in this case to suggest Johnson posed any such threat at the time of his detention or subsequent frisking by Officer Trevizo. Furthermore, she expressed concern over potential racial profiling implications of allowing officers broad discretion in conducting searches without specific cause for alarm beyond mere participation in criminal activity.