State v. Henry, 237 N.C. App. 311 (Nov. 18, 2014)

Even if the defendant had properly preserved the issue, a frisk conducted during a valid traffic stop was proper where the officer knew that the defendant had prior drug convictions; the defendant appeared nervous; the defendant deliberately concealed his right hand and refused to open it despite repeated requests; and the officer knew from his training and experience that people who deal drugs frequently carry weapons and that weapons can be concealed in a hand.