People v. Grant, 951 N.E.2d 1153

Grant was arrested for violating Chicago Municipal Code 10-8-515 after shouting 'dro, dro' at a passing car near a known narcotics area; first custodial search yielded cannabis in four baggies.
Officers on a narcotics suppression mission detained Grant within 5–10 feet of where he stood; he was handcuffed and taken to the station.
A second custodial search at the station recovered four baggies containing a white substance (crack cocaine) and $160 in cash.
Circuit court denied the motion to quash arrest and suppress; after a stipulated bench trial, Grant was convicted of Class 4 possession of cocaine and sentenced to three years.
The issue on appeal was whether the arrest was supported by probable cause, with de novo review by the appellate court.
The appellate court reversed, holding there was no probable cause to arrest for the ordinance violation, thus suppressing the evidence and vacating the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there probable cause to arrest for the ordinance violation?	Grant—no probable cause; shouting 'dro, dro' in a known narcotics area does not prove a crime.	State—yelling a cannabis slang term constitutes probable cause to arrest for solicitation of unlawful business.	No probable cause; arrest unlawful; conviction reversed.

People v. Mendoza, 62 Ill.App.3d 609 (1978) (probable cause and suppression context cited)
Beck v. Ohio, 379 U.S. 89 (1964) (probable cause standard for arrests)
Lippert, 89 Ill.2d 171 (1982) (probable cause standards for arrest; search incident context)
Arizona v. Gant, 556 U.S. 332 (2009) (searches incident to arrest; rule for warrantless searches)
Ornelas v. United States, 517 U.S. 690 (1996) (de novo review of probable cause determinations)
Tisler, 103 Ill.2d 226 (1984) (probable cause standards; magistrate-like scrutiny for warrantless searches)
Powell, 315 Ill.App.3d 1136 (2000) (adequacy of ordinance-violation complaints; sufficiency to inform nature and cause)