Illinois Appellate Court
Criminal Court
Possession of a Controlled Substance
Defendant was convicted, after jury trial, of knowingly possessing substance containing cocaine. Court properly denied his pretrial motion to suppress. Police had warrant to search his home for evidence related to a shooting, and during search detective found substance, inside knotted, plastic bags, which were concealed in a larger plastic bag, under bed sheets. No ineffective assistance of counsel in arguing that search was unreasonable, as detective had probable cause to seize the substance as soon as he discovered it hidden beneath sheets in packaging commonly used to store illicit drugs. (HOLDRIDGE, specially concurring; OBRIEN, specially concurring.)