People v. Varnauskas

Defendant was convicted, after jury trial, of 2 counts of controlled substance trafficking. Court properly denied motion to suppress evidence. Part of bicycle rack affixed to vehicle covered at least 2 digits of license plate. Officer reasonably believed condition of vehicle being driven by Defendant violated Section 3-413(b) of Vehicle Code, due to obstruction of license plate. Evidence of canine alerting to odor of drugs provided probable cause for troopers to believe that vehicle contained drugs and to support search of vehicle. Probable cause did not dissipate when troopers relocated vehicle so a complete, thorough search could be done in safer location with better lighting. (SCHMIDT, concurring; McDADE, dissenting).