People v. Jarrell C. (In Re Jarrell C.)
95 N.E.3d 1153
| Ill. App. Ct. | 2017Background
- On July 22, 2016, officers in an unmarked car observed respondent (age 18) near a high-crime area and follow him into a currency exchange where he was buying a bus card.
- Officers testified they saw respondent clutching his waistband/crotch area and, based on prior experience, suspected he was concealing a gun.
- Inside the store officers directed respondent to lift his shirt and place his hands on a railing; Commander Escamilla recovered a handgun from respondent’s front waistband and drugs were later recovered.
- Respondent had an unrelated juvenile arrest warrant issued a month earlier; there was no evidence the officers knew of this warrant at the time of the stop/search.
- The trial court found the stop lacked reasonable suspicion but ruled the unrelated warrant attenuated the illegality and denied the suppression motion.
- The appellate court reversed, finding the stop was an unlawful seizure and the unknown warrant did not break the causal chain to justify admission of the seized evidence.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Respondent) | Held |
|---|---|---|---|
| Whether officers had reasonable, articulable suspicion to seize respondent | Observed clutching waistband in high-crime area plus nervous behavior gave reasonable suspicion of concealed weapon | Clutching waistband/crotch is innocuous and insufficient; video corroborates no waistband hold inside store | Court: seizure lacked reasonable suspicion (stop unlawful) |
| Whether existence of an outstanding arrest warrant attenuated the taint of the unlawful stop | Existence of a valid arrest warrant (even unrelated) severs causal chain and permits admission | Warrant was unknown to officers at time of stop/search, so it could not be an intervening circumstance | Court: warrant did not attenuate because officers did not learn of it before discovery of evidence; suppression required |
| Whether police misconduct was purposeful or flagrant (affecting attenuation) | Officers acted on reasonable, good-faith judgment; not flagrant | Stop was unjustified; but even if unlawful, misconduct was not deliberate | Court: misconduct not purposeful or flagrant, this factor favors attenuation but is insufficient given other factors |
Key Cases Cited
- People v. Pitman, 211 Ill. 2d 502 (Illinois 2004) (standard of review for suppression rulings; mixed questions of law and fact)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (Terry stop standard: specific, articulable facts supporting reasonable suspicion)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (Fourth Amendment limits on vehicle stops and requirement that suspicion exist prior to detention)
- Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (three-factor attenuation analysis: temporal proximity, intervening circumstances, flagrancy)
- Utah v. Strieff, 136 S. Ct. 2056 (U.S. 2016) (holding that discovery of a valid outstanding warrant can be an intervening circumstance breaking causal chain)
- People v. Estrada, 394 Ill. App. 3d 611 (Ill. App. Ct. 2009) (reasonable-suspicion principles and requirement evidence supporting suspicion predate the stop)