City of Lake Forest v. Martinez-Galarza

Illinois Appellate Court
Criminal Court
Traffic Stop
Citation
Case Number: 
2025 IL App (2d) 240352
Decision Date: 
Tuesday, April 29, 2025
District: 
2d Dist.
Division/County: 
Lake Co.
Holding: 
Reversed and remanded.
Justice: 
SCHOSTOK

Defendant was arrested and charged by the City of Lake Forest with driving under the influence of alcohol. The trial court granted defendant’s motion to quash his arrest and to suppress evidence on the basis that the traffic stop was unreasonably prolonged and the City appealed. The appellate court reversed and remanded, finding that the officer did not unreasonably prolong the traffic stop by explaining to the defendant the reasoning for the issuance of a warning for an equipment violation. (HUTCHINSON and JORGENSEN, concurring)