People v. Jordan, 2012 IL App (2d) 100629

Traffic stop occurred in August 2009; Jordan was a passenger in a Blazer driven by Zaloudek, stopped for a seatbelt violation.
Deputy Netter ran warrant checks; Zaloudek was on MSR (parole) and no warrants were found for either occupant.
Deputy Netter questioned defendant remotely from Zaloudek to keep her out of earshot, then detained her in the squad car with the rear window lowered.
Zaloudek was questioned and, later, a search of his vehicle was conducted; no contraband was found.
Approximately 15 minutes later, Netter planned to call a canine unit; after additional questioning, defendant admitted cannabis on her person and in a bag in the vehicle.
Defendant’s admissions and the cannabis were suppressed by the trial court as fruits of an unlawful detention and Miranda violation; the State appealed via Rule 604(a)(1).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant's statements were obtained in violation of Miranda because of custody during interrogation	Jordan	Jordan	Custodial interrogation; Miranda warnings required; suppression affirmed
Whether the suppression was proper as fruit of an unlawful interrogation	Jordan	Jordan	Evidence inadmissible as fruit of improper interrogation; suppression affirmed
Whether the initial traffic stop and subsequent searches were permissible under current law	Jordan	Jordan	Court assumes stop valid for analysis but bases decision on Miranda grounds; suppression sustained

Berkemere v. McCarty, 468 U.S. 420 (U.S. 1984) (traffic-stop custody rules; Miranda warnings not bright-line at outset)
People v. Oliver, 236 Ill.2d 448 (Ill. 2010) (standards for reviewing suppression rulings (fact-finding and de novo))
People v. Slater, 228 Ill.2d 137 (Ill. 2008) (custody determination factors after traffic stop)
People v. Melock, 149 Ill.2d 423 (Ill. 1992) (custody factors and interrogation atmosphere)
People v. Brown, 136 Ill.2d 116 (Ill. 1990) (factors affecting the coercive atmosphere of interrogation)