What is the standard of care of a police officer in making a traffic stop on a highway?

As this court explained in Ramirez v. Plough, Inc. (1993) 6 Cal.4th 539, 546, 25 Cal.Rptr.2d 97, 863 P.2d 167, it is more accurate to view defendants' present argument not as relating to the threshold question of the existence of a duty itself defendants no longer claim that an officer owes no duty of care to passengers in a vehicle stopped by the officerbut rather as relating to the appropriate "standard of care."⁸ Defendants argue in essence that we should declare, as part of the governing standard of care, that a law enforcement officer, in making a traffic stop on a highway, always satisfies the duty of reasonable care so long as the officer stops a vehicle at any location off of the travel lanes of a highwaywithout regard to whether the stop is made in the center median of a freeway or on the right shoulder, and apparently also without regard to the width of the median or shoulder on which the stop is made, how far off the roadway the stopped car is located, the visibility of the stopped vehicle to oncoming traffic at the location of the stop, or any other potentially relevant circumstance.