People v. Lindsey

Illinois Supreme Court PLAs
Criminal Court
Search and Seizure
Citation
PLA issue Date: 
January 31, 2019
Docket Number: 
No. 124289
District: 
3rd Dist.

This case presents question as to whether trial court properly denied defendant’s motion to suppress drugs found in his motel room after police dog conducted free air sniff of door handle and seams of door to defendant’s motel room, and after officer had obtained search warrant based on dog’s alert to presence of drugs inside defendant’s room. Appellate Court, in reversing trial court, found that dog sniff in common area outside defendant’s motel room violated defendant’s 4th Amendment rights, since he had reasonable expectation of privacy, under circumstances where drug smell was undetectable by officer outside of defendant’s room, and where officer used extra-ordinary means to detect what was inside defendant’s motel room. (Partial dissent filed.)