People v. Cummins

Illinois Appellate Court
Criminal Court
Exigent Circumstances
Citation
Case Number: 
2025 IL App (2d) 230516
Decision Date: 
Tuesday, July 8, 2025
District: 
2d Dist.
Division/County: 
Kane Co.
Holding: 
Reversed.
Justice: 
SCHOSTOK

The State filed an interlocutory appeal of a trial court order granting the defendant’s motion to suppress evidence that police obtained via a warrantless and non-consensual search of the defendant’s residence. The State argued that search was valid under the emergency exception to the fourth amendment’s warrant requirement. The appellate court agreed and reversed, explaining that the facts established that the officers had reasonable grounds to believe that someone was in the house and that person needed immediate assistance. (JORGENSEN and BIRKETT, concurring)