Illinois Supreme Court
Criminal Court
Plain View Doctrine
Defendant appealed from his conviction of unlawful possession of a controlled substance, contending that the circuit court erred when it denied his motion to suppress because the contraband was not in plain view when police officers investigated a gas leak in his home. The Illinois Supreme Court agreed and reversed, finding that the contraband was not in plain view because it was located in a chained and locked cabinet in the defendant’s kitchen. (THEIS, OVERSTREET, HOLDER WHITE, CUNNINGHAM, and ROCHFORD, concurring and NEVILLE, specially concurring)