People v. Hackett
2012 IL 111781
Ill.2012Background
- Hackett was stopped in Joliet for allegedly improper lane usage under 11-709(a).
- Deputy Blouin observed two brief deviations of Hackett’s vehicle into the right lane, separated by several seconds.
- Circuit court granted suppression, finding no probable cause or reasonable grounds for the stop.
- Appellate Court affirmed, distinguishing Smith and requiring a reasonably appreciable distance for a 11-709(a) violation.
- Illinois Supreme Court reversed, holding the stop was at least investigatory and justified, and remanded for further proceedings.
- Court clarifies that distance traveled is not dispositive under 11-709(a) when there are multiple, unexplained deviations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the deputy had reasonable grounds to stop for lane deviation | State contends reasonable suspicion/probable cause. | Hackett contends no grounds to stop. | Stop justified as investigatory, not requiring probable cause. |
| Does Smith require a distance threshold for 11-709(a) violations? | State relies on Smith’s reasoning. | Hackett argues Smith controls; no distance required. | Distance not dispositive; multiple deviations suffice for investigatory stop. |
| What standard governs the stop—probable cause or reasonable suspicion? | State argues reasonable suspicion or probable cause. | Hackett argues need for more than suspicion. | Fourth Amendment allows investigatory stop based on reasonable suspicion; not need probable cause. |
Key Cases Cited
- People v. Smith, 172 Ill. 2d 289 (1996) (probable cause not required for investigatory stop; 11-709(a) violation when not within one lane)
- Close v. United States, 238 Ill. 2d 497 (2010) ( Terry stop with articulable facts, not required to meet probable cause)
- Gonzalez v. City of Chicago, 204 Ill. 2d 220 (2003) (probable cause vs. reasonable suspicion distinction in vehicle stops)
- McDonough v. State, 239 Ill. 2d 260 (2010) ( Fourth Amendment reasonableness; standard for traffic stops)
- Luedemann v. City of Chicago, 222 Ill. 2d 530 (2006) (standard for reviewing suppression rulings; de novo for legal questions)