Defendant was found guilty of unlawful cannabis trafficking, unlawful possession with intent to deliver, and unlawful possession of cannabis and was sentenced to prison for 10 years. Defendant appealed, arguing that the circuit court erred by denying his motion to suppress evidence because the investigating officer did not have a reasonable, articulable suspicion to seize defendant’s vehicle and because the officer did not have probable cause to allow a drug sniffing dog to search the exterior of the vehicle. The appellate court affirmed, finding that a dog sniff of the exterior of a car parked in a public place was not a search or a seizure and that the dog’s alert gave the officer probable cause to search the vehicle. (TURNER and ZENOFF, concurring)
Illinois Appellate Court
Criminal Court
Motion to Suppress