Merely being outside a house being searched under a warrant does not justify a patdown
FourthAmendment.com:
Merely standing outside of a house where a search warrant is being executed does not justify a patdown under Ybarra. People v. Sandoval, 2008 Cal. App. LEXIS 772 (3d Dist. May 23, 2008).
Volunteer fireman from Texas who was driving on I-10 in Louisiana who used his emergency lights to stop defendant’s car which was being operated erratically was not state action. State v. Lavergne, 2008 La. App. LEXIS 736 (1st Cir. May 2, 2008).*