People v. Gaytan
32 N.E.3d 641
Ill.2015Background
- Gaytan was a passenger in a car stopped for a ball-type trailer hitch obstructing the rear license plate under 625 ILCS 5/3-413(b).
- Police detected cannabis odor during the stop and found cannabis in a diaper bag belonging to Gaytan; he was charged with unlawful possession with intent to deliver and unlawful possession of cannabis.
- Circuit court denied suppression; Gaytan was convicted at a bench trial after a stipulated time-probation sentence.
- Appellate Court reversed, holding 3-413(b) prohibits only materials attached to the plate, not trailer hitches, so the stop was unlawful; State sought review.
- The court examined whether 3-413(b) is ambiguous, applied lenity, and, following Heien, held that an objectively reasonable but mistaken belief about the law can justify a vehicle stop; the stop was constitutional under both the state and federal constitutions, reversing the appellate court and reinstating Gaytan’s convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 3-413(b) prohibit objects not attached to the plate (e.g., trailer hitches) obstructing visibility? | State advocates broad reading: any obstruction by any object violates the statute. | Gaytan argues only attached items (glasses, covers) are prohibited; hitch is not within the clause. | Statute ambiguous; interpret as limited to attachments to the plate. |
| If 3-413(b) is ambiguous, does the rule of lenity justify upholding the stop? | Lenity supports a reasonable, albeit mistaken, interpretation that the hitch violated the statute. | Lenity should not override a clear statutory interpretation; longer-standing rules may differ. | Lenity applied to adopt the narrower attachment-based reading; stop upheld. |
| Does Heien’s reasonable mistake of law apply to justify the stop under the Illinois Constitution? | Court should apply Heien’s reasoning to allow a reasonable mistake of law to justify the stop. | Not necessary if statute is clear; but if ambiguous, Heien supports upholding the stop. | Yes; objectively reasonable mistake of law can validate the stop under both state and federal constitutions. |
Key Cases Cited
- Mapp v. Ohio, 367 U.S. 643 (U.S. Supreme Court 1961) (standard for unreasonable searches and seizures applies to states)
- People v. Absher, 242 Ill. 2d 77 (Illinois Supreme Court 2011) (two-part test for suppression appeals; de novo legal review)
- Prado Navarette v. California, 134 S. Ct. 1687 (U.S. Supreme Court 2014) (reasonable, objective basis for suspicion required in traffic stops)
- Heien v. North Carolina, 135 S. Ct. 530 (U.S. Supreme Court 2014) (reasonable mistake of law can justify a stop; objective standard; not a faultless law)
- People v. Sutherland, 223 Ill. 2d 187 (Illinois Supreme Court 2006) (standards for suppression and constitutional protections)