In Ohio, the answer is no. The United States Supreme Court decided this issue in the case of Pennsylvania v. Mimms (1977), 434 U.S. 106.
Some people think that they can sit in their vehicle by the roadside with the window barely cracked open and speak with the officer. If the officer allows them to do this that is fine, but if the officer requests that you get out of your car, then you have to get out and talk to him outside of the car. The idea that the officer’s request that you get out of the car is an arrest (lacking probable cause) is not legally tenable in Ohio.
When a person is being detained at the roadside pursuant to a traffic stop, it is common practice for the police to request that the person exit their vehicle. The police will argue that they can keep a better handle on the situation if they have you outside your car.
For instance, it is easier for you to reach for a gun without the officer noticing while you are still in your car. The additional intrusion represented by requiring that a person to get out of his or her car is de minimis, and is not protected by the Fourth Amendment to the United States Constitution. As such, a police officer’s order that you get out of your car is not an arrest (although if you fail to follow his lawful order, you can be arrested).
It is important to understand that the police do not have to give you the Miranda Rights in order to arrest you, or in order to keep you under arrest. The police only need to read you the Miranda rights if they wish to question you after the arrest and introduce your answers in Court.