Illinois Supreme Court
Criminal Court
Probable Cause
Defendant was charged with unlawful possession of a controlled substance, after officer searched his vehicle and found a small rock of crack-based cocaine under the driver's seat. Officers had probable cause to search Defendant's vehicle. Officer saw Defendant delay in pulling over, and saw a loose "bud" in the backseat and smelled strong odor of cannabis. The facts available to officer would put a reasonably prudent person on notice that the vehicle contained contraband or evidence of a crime.(BURKE, KILBRIDE, GARMAN, THEIS, and NEVILLE, concurring.)