People v. Marshall 

Defendant was convicted of felony driving on revoked license after bench trial. Defendant was denied effective assistance of counsel, as counsel failed to file motion to suppress the revoked license which would likely have been granted. Police officer testified that he saw Defendant driving only for 20-25 seconds before he pulled over into "No Parking" zone, but Defendant and passenger remained in the car, and City of Chicago ordinance defines "No Parking" zones as requiring that vehicles not be left unoccupied there. Officer turned on his flashing lights when he pulled behind vehicle, and this was a display of force such that a reasonable person would not have felt free to leave nor to refuse to produce license and insurance card. Thus, Defendant, who produced his state ID, leading officer to learn that his license was revoked, was subjected to unlawful seizure of his revoked license. (KARNEZIS and CONNORS, concurring.)