Can a police officer order a passenger to stay in the car?

Castellon attempts to distinguish Maryland v. Wilson, supra, 519 U.S. 408 on the ground that while a police officer may order a passenger to exit a vehicle for safety purposes, the officer may not order a passenger to stay in a vehicle without reasonable suspicion to detain him or her because the passenger is free to leave. We disagree; whether the passenger is ordered to stay in the car or exit the vehicle is a distinction without a difference. (See id. at p. 414 ["The only change in their circumstances which will result from ordering them out of the car is that they will be outside of, rather than inside of, the stopped car."].) Further, the inconvenience and intrusion are certainly less when the passenger is simply ordered to remain seated in the car than when he or she is ordered out of the vehicle. If the minimal additional intrusion on the personal liberty of the passenger ordered out of the vehicle cannot trump the safety of the officer, then surely the slight inconvenience of ordering the passenger to remain seated can be justified by an officer's concerns.