People v. Dossie

Illinois Supreme Court PLAs
Criminal Court
Search and Seizure
Citation
PLA issue Date: 
September 29, 2021
Docket Number: 
No. 127412
District: 
1st Dist.

This case presents question as to whether trial court properly granted defendant’s motion to quash his arrest that was based on investigative alert issued by Chicago Police Dept. and to suppress incriminating statement that defendant made while under his warrantless arrest. While trial court found that use of investigative alert rather than arrest warrant was unconstitutional, especially where there were no exigent circumstances at time of defendant’s arrest, Appellate Court, in reversing trial court, found that trial court erred in ruling that defendant’s arrest was unconstitutional simply because it was based on investigative alert. Moreover, Appellate Court found that there was probable cause to arrest defendant, where: (1) witness identified defendant near scene of shooting with handgun in his hand and driving away after witness heard gunshots; and (2) video evidence corroborated fact that witness was at scene of crime.