People v. Martin
2017 IL App (1st) 143255
| Ill. App. Ct. | 2017Background
- On June 9, 2013, police observed what they believed was a drug transaction outside 5154 W. Fulton; defendant exchanged a small item and money with another man, who later handed officers a bag of suspected heroin.
- Officers approached 5154 W. Fulton (a two‑flat owned by defendant’s mother), detained defendant and another man, and Officer Warner reached into the inside doorframe above the exterior door and recovered a blue bag containing suspected heroin without a warrant or consent.
- At the suppression hearing the mother testified she owned and lived in the first‑floor unit, the second floor was unoccupied, the hallway/vestibule beyond the outer door was private, and she posted a “no trespassing” sign and locked the door.
- The trial court denied the motion to quash/suppress, and after a bench trial convicted defendant of possession of a controlled substance (lesser‑included offense) and sentenced him to five years’ imprisonment.
- On appeal the court considered whether the warrantless physical intrusion into the doorway/vestibule was a Fourth Amendment search under Florida v. Jardines and Katz, and whether any exception (exigent circumstances or good‑faith reliance on precedent) justified the entry or seizure.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was recovery of the blue bag a Fourth Amendment search? | Not a search because officers did not enter the home and the area was a common area. | It was a search: officer physically intruded into protected curtilage/threshold. | Court: It was a warrantless search under Jardines—officer physically intruded into a constitutionally protected area. |
| Was 5154 W. Fulton a common area (no expectation of privacy) or a single‑family home? | Characterized as a multi‑unit/common area accessible to others. | Building was a family‑occupied two‑flat owned by defendant’s mother with private vestibule and no tenants — treated as a single‑family home. | Court: Treated the two‑flat as a single‑family home given facts; doorway/threshold was part of protected area. |
| Did exigent circumstances justify the warrantless entry/seizure? | Officers feared destruction/ removal of evidence by unknown participant and had probable cause. | No exigency: multiple officers on scene, defendant and Mason in custody, speculative that unknown man entered and would destroy evidence. | Court: No exigent circumstances; State failed to show particularized risk of destruction and officers could have secured the scene or obtained a warrant. |
| Does the good‑faith (binding precedent) exception to exclusion apply? | Officers reasonably relied on First District cases holding common areas lack protection. | Precedent inapplicable because facts showed a family‑occupied two‑flat, not a multi‑unit common area. | Court: Good‑faith exception inapplicable because precedent cited (Carodine, Lyles) concerned multi‑unit common areas and did not reasonably apply here. |
Key Cases Cited
- Florida v. Jardines, 133 S. Ct. 1409 (2013) (use of officers to investigate home’s curtilage can be a Fourth Amendment search when it involves an unlicensed physical intrusion)
- Katz v. United States, 389 U.S. 347 (1967) (Fourth Amendment protects people’s reasonable expectations of privacy)
- People v. Burns, 2016 IL 118973 (Ill. 2016) (applies Jardines to locked multi‑unit building landings and recognizes curtilage in apartment common areas)
- United States v. Dunn, 480 U.S. 294 (1987) (factors for determining curtilage of a home)
- Payton v. New York, 445 U.S. 573 (1980) (Fourth Amendment draws firm line at the entrance to the house)
- Kyllo v. United States, 533 U.S. 27 (2001) (any physical intrusion into the home to obtain information is impermissible without a warrant)
- Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule does not apply when officers act in objectively reasonable reliance on binding precedent)