People v. Molnar

Defendant was convicted of unlawful possession of a controlled substance. Police officer, responding to a call about a possible altercation, saw a pill bottle on front passenger area where Defendant had been sitting. Court did not err in denying Defendant's motion to suppress a pill bottle, which had no prescription label but contained a plastic baggie and Xanax pills. Although police seized bottle without a warrant, the seizure was valid under the plain-view doctrine because the bottle's incriminating nature was immediately apparent. Officer had probable cause to believe that Defendant lacked a prescription for the pills and thus was committing a crime.  (McLAREN and BIRKETT, concurring.)