Court granted Defendants' motions to quash search warrant and suppress evidence. Complaint for search warrant alleged that an unknown person possessed what Doe (a confidential source) believed to be heroin, based on Doe's unspecified prior experience, at the location described in the complaint. Complaint was insufficient to cause a reasonable person to believe that evidence of unlawful possession or delivery of a controlled substance was at the described location. Allegations were so generic and lacking in any indicia of reliability that officers who executed search warrant could not have reasonably believed that warrant was valid. Thus, the good-faith exception to the exclusionary rule does not apply. (McDADE, concurring; CARTER, dissenting.)
Illinois Appellate Court
Criminal Court
Search and Seizure