People v. Ellis

Defendant was convicted, after bench trial, of being an armed habitual criminal. When officers arrested Defendant and confiscated the gun admitted into evidence at trial, arresting officers had probable cause to believe that he was in violation of a provision of the Illinois aggravated unlawful use of a weapon (AUUW) statute that was later deemed facially unconstitutional. Where probable cause exists at the time of a defendant's arrest, the exclusionary rule does not apply, and the court need not consider the good faith exception to that rule. The Illinois Supreme Court's 2017 decision in People v. Holmes is still controlling precedent. (CONNORS and HARRIS, concurring.)