People v. Smith

Defendant was convicted of being an armed habitual criminal. On appeal, defendant argued that the trial court should have suppressed the firearm that was discovered during a traffic stop and that the State failed to find him guilty beyond a reasonable doubt. The appellate court reversed, finding that the trial court erred in denying defendant’s motion to suppress the firearm evidence recovered from the search of a bag in the backseat of the vehicle because the police lacked probable cause to search the bag and the firearm was the only evidence that supported defendant’s conviction. (LAMPKIN and MARTIN, concurring)