People v. Colyar 

Police officers, who observed a car in motel parking lot with its engine running, noticed a bullet sticking up in a plastic bag on the center console. Officers immediately removed occupants from vehicle, handcuffed them, and placed each in custody without determining whether bullet was evidence of a crime, and without making inquiry of whether occupants had a FOID card or were convicted felons. Officers improperly escalated the investigative stop into a full arrest of the Defendant and then engaged in search of vehicle as incident to the arrest; thus, court properly granted Defendant's motion to suppress the bullets and gun unlawfully seized by the police. (HALL, concurring; LAMPKIN, dissenting.)