People v. Meo

Illinois Appellate Court
Criminal Court
DUI
Citation
Case Number: 
2018 IL App (2d) 170135
Decision Date: 
Wednesday, March 14, 2018
District: 
2d Dist.
Division/County: 
DeKalb Co.
Holding: 
Reversed and remanded.
Justice: 
BIRKETT

(Court opinion corrected 3/20/18.) Defendant was charged with DUI and obstructing a peace officer. Court erred in granting Defendant's motion to quash arrest and suppress evidence. Tip from clerk at gas station, who reported that there was a drunk driver in the building, was sufficiently reliable to justify stop. Tip was not anonymous, as clerk who made call to police was readily identifiable. Clerk specifically described driver of vehicle and provided make and color of vehicle; tip was reliable as it was based on contemporaneous events and provided enough information to allow officer to identify Defendant as the person referred to by clerk. Tip was sufficiently detailed to permit reasonable inference of DUI, given clerk's description of Defendant's driving and clerk's close proximity to Defendant and ability to observe him in store. Officer had probable cause to arrest Defendant for DUI. (McLAREN and BURKE, concurring.)