What cannot be frisked during a vehicle Terry frisk?

A vehicle Terry frisk, often referred to as a "protective search," is conducted during a detention when there is reasonable suspicion that a weapon may be present and poses a danger to the officer or others. The key purpose of such a frisk is to ensure the safety of the officer by checking areas where a weapon could be hidden.

Locked containers cannot be frisked during a vehicle Terry frisk because, by their nature, they are secured and not readily accessible. Officers cannot reasonably check inside these containers without a warrant or probable cause, as opening a locked container would violate the individual's expectation of privacy and the Fourth Amendment protections against unreasonable searches.

In contrast, components such as open glove compartments and door pockets can be accessed without compromising the rights of occupants to the same extent as locked containers. These parts of the vehicle are considered areas where a weapon might reasonably be concealed and can be checked during a Terry frisk to ensure officer safety. Hence, the ability to conduct a frisk is limited by the nature of the container's accessibility and security.