People v. Gaytan

Illinois Supreme Court
Criminal Court
Search & Seizure
Citation
Case Number: 
2015 IL 116223
Decision Date: 
Thursday, May 21, 2015
District: 
4th Dist.
Division/County: 
McLean Co.
Holding: 
Appellate court reversed; circuit court affirmed.
Justice: 
BURKE
(Correcting court designation.) An objectively reasonable, though mistaken, belief as to the meaning of a law may form basis for costitutionally valid vehicle stop under Illinois constitution. It was objectively reasonable for officers to believe that trailer hitch, on vehicle in which Defendant was a passenger, violated Section 3-413(b) of Vehicle Code. Thus, traffic stop was constitutionally valid under state and federal constitutions. Section 3-413(b) is ambiguous and, applying rule of lenity, it prohibits only materials which are attached to a license plate, and thus a trailer hitch does not violate that section. (GARMAN, FREEMAN, THOMAS, KILBRIDE, KARMEIER, and THEIS, concurring.)