People v. Martin
2017 IL App (1st) 143255
| Ill. App. Ct. | 2017Background
- Defendant Derrick Martin was convicted by bench trial of possession of a controlled substance; sentenced to five years.
- Defendant moved to suppress evidence from a warrantless search of 5154 West Fulton Street, Chicago.
- Mother Perlene West owned the two-flat building; she lived on the first floor and no one resided on the second floor on June 9, 2013.
- Officers surveilled a drug transaction near 5154 West Fulton, observed defendant enter the building, reach into a doorway, and place a blue bag inside; later, a bag containing heroin was found on Mason.
- Officers recovered the blue bag from above the interior doorframe after entering the private/common area of the building; no warrant or consent was obtained.
- Trial court denied suppression; on appeal, the court held suppression was warranted and reversed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrantless entry/search violated the Fourth Amendment | People argues no Fourth Amendment violation; entry was permissible. | Martin argues the intrusion into the private doorway/curtilage was a search violating Jardines and Katz. | Suppression required; warrantless intrusion deemed a search under Jardines/Katz. |
| Whether 5154 West Fulton is a private single-family home for Fourth Amendment purposes | Prosecution treats building as a multi-unit dwelling with open common areas. | Defendant's mother owned and lived there; building treated as private home. | Building treated as a single-family home for Fourth Amendment purposes. |
| Whether exigent circumstances or plain view justified the entry and seizure | Exigent circumstances or plain view justified warrantless seizure. | No exigent circumstances and plain view does not apply. | Exigent circumstances did not exist; plain view not satisfied; suppression affirmed. |
| Whether good-faith reliance on binding precedent excused the conduct | State relied on Carodine/Lyles to justify common-area searches. | These precedents do not apply to a single-family home; cannot excuse. | Good-faith exception rejected; exclusionary rule applied; suppression affirmed. |
Key Cases Cited
- People v. Carodine, 374 Ill. App. 3d 16 (2007) (common areas not protected when open to others (Illinois))
- People v. Lyles, 332 Ill. App. 3d 1 (2002) (common areas open to others; limits on Fourth Amendment scope)
- Payton v. New York, 445 U.S. 573 (1980) (entrance to home is a core Fourth Amendment protection)
- Kyllo v. United States, 533 U.S. 27 (2001) (physical intrusion into a home is highly regulated)
- Florida v. Jardines, 569 U.S. _ (2013) (dog-sniff at home boundary constitutes a search when intruding beyond license)
- United States v. Villegas, 495 F.3d 761 (7th Cir. 2007) (duplex privacy considerations; building as single dwelling dependent on facts)
- United States v. King, 227 F.3d 732 (6th Cir. 2000) (privacy in basement area can depend on living arrangements)
- Hassan, 253 Ill. App. 3d 558 (1993) (plain view limitations in Illinois)
- People v. Burns, 2016 IL 118973 (Illinois Supreme Court) (Jardines applied to multi-unit dwellings; curtilage analysis clarified)
- Davis v. United States, 564 U.S. 229 (2011) (good-faith exception limits)