People v. Harris

Illinois Appellate Court
Criminal Court
Warrantless Arrest
Separation of Powers Doctrine
Citation
Case Number: 
2022 IL App (3d) 200234
Decision Date: 
Wednesday, February 23, 2022
District: 
3d Dist.
Division/County: 
Peoria Co.
Holding: 
Affirmed.
Justice: 
O'BRIEN

Defendant appealed his conviction for unlawful use of a weapon by a felon, arguing that the trial court erred in denying his motion to quash and suppress because there were no reasonable grounds, exigent circumstances, or good faith reason to support the arrest and search of defendant absent an arrest warrant. Defendant also argued that the Peoria Police Department’s use of an investigative alert violates the separation of powers doctrine. The appellate court affirmed finding that the use of alerts to disseminate information among officers does not conflict with the authority of the courts and that the investigative alert provided reasonable grounds to make a warrantless arrest. (DAUGHERITY and LYTTON, concurring)