How have the courts in Canada dealt with the issue of personal injury cases involving personal injury claims?

For example, in Cloutier v. Langlois, two police officers stopped a practicing Montreal lawyer for making an improper right turn in his vehicle in breach of a municipal by-law. As the police tried to collect his driver’s licence and other vehicle documentation, the lawyer became “heated.” While writing the ticket, the officers learned that there was an outstanding warrant for the arrest of the lawyer for unpaid traffic fines. The police had the lawyer exit his vehicle, whereupon they performed a frisk search. The police had the lawyer place his hands on the hood of the police car, spread his legs, and they patted him down. He was then taken to the police station in the squad car. The lawyer argued that his arrest and search were illegal.