People v. Harris, 957 N.E.2d 930

Defendant Derek Harris was arrested April 23, 2010 for aggravated unlawful use of a weapon; a handgun was recovered during a protective search.
Defendant moved to quash the arrest and suppress evidence; the trial court initially denied then granted suppression.
The State appealed under Supreme Court Rules 604(a)(1) and 606 to challenge the suppression ruling.
Officers Goon and Doolin pursued Harris after he fled from them during a field interview in a high‑crime area.
The trial court found flight suggested reasonable suspicion under Wardlow, but on reconsideration vacated and suppressed the weapon.
The appellate court affirmed suppression, concluding the stop lacked a valid Terry basis and the protective search was unlawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the investigatory stop justified by reasonable suspicion?	State argues Harris's flight in a high‑crime area shows reasonable suspicion.	Harris contends there was no particularized, articulable suspicion.	No; stop not justified.
Was the protective search justified given no valid stop?	State contends search incident to stop was permissible to ensure safety.	Harris argues no valid stop, hence no basis for a protective search.	No; search invalid.

Wardlow, 528 U.S. 119 (2000) (high-crime area plus evasive flight support reasonable suspicion but not a bright-line rule)
Thomas, 198 Ill. 2d 103 (2001) (standard for reviewing suppression rulings; Terry framework applied in Illinois)
Adams v. Williams, 407 U.S. 143 (1972) (protective frisk allowed if stop proper and suspect armed and dangerous)
People v. F.J., 315 Ill. App. 3d 1053 (2000) (limits on frisk when no proper stop or articulable suspicion; LaFave guide quoted)
United States v. Wright, 485 F.3d 45 (2007) (discusses high crime area and temporal proximity in stop analyses)