Illinois Appellate Court
Criminal Court
Search and Seizure
Defendant was stopped for traffic violation, then found to be driving on revoked license and with no insurance. After Defendant was handcuffed and in squad car, police performed inventory search of vehicle prior to having it towed, per their procedure of inventorying and towing any vehicles lacking insurance. Court improperly granted Defendant's motion to suppress plastic bag containing cocaine which inventorying officer viewed in driver's side door, as it was in course of reasonable police procedure. Supreme Court's Arizona v. Gant decision did not expressly overrule cases in which courts have sanctioned inventory searches pursuant to proper impoundment of vehicle. (HOLDRIDGE and WRIGHT, concurring.)