People v. Hernandez

Defendant was convicted, after bench trial, of unlawful delivery of a controlled substance. Detective testified that narcotics traffickers often do “heat runs” as countersurveillance, to find out if they are being watched by law enforcement, by taking an out-of-the-way route to an actual destination.Evidence sufficiently proved that Defendant served as a lookout while his father and brother conducted a drug transaction. Detective described how Defendant conducted a heat run, driving a circuitous route around the city with no apparent destination in mind. (BIRKETT and SPENCE, concurring.)