People v. McGhee, 162 N.E.3d 1080

Police stopped a car driven by Antonio McGhee after a reported traffic violation; front-seat passenger (Pugh) made furtive movements and held/opened beer bottles.
Officers observed open containers and searched the passenger area; they found sealed beers and then a locked glove compartment that they opened with a key from the ignition and later with a key found in Pugh’s shoe.
Inside the locked glove compartment officers recovered a revolver and counterfeit currency; McGhee was charged with unlawful use/possession of a weapon by a felon (UUWF) and armed habitual criminal (AHC) based on prior Illinois and Iowa burglary convictions.
McGhee moved to suppress the gun (arguing no warrant, no consent, no probable cause); the trial court denied the motion and admitted the Iowa conviction at bench trial; McGhee was convicted of both offenses.
On appeal the court affirmed denial of suppression (automobile exception justified the glove-compartment search) but reversed the AHC conviction, holding the State failed to prove the Iowa second-degree burglary qualified as an Illinois "forcible felony." Case remanded for sentencing on the merged UUWF count.

Issue	People’s Argument	McGhee’s Argument	Held
Were officers justified in warrantless search of locked glove compartment?	Probable cause to search vehicle for open containers; glove compartment within passenger area; automobile-exception (and search-incident-to-arrest) applies.	No probable cause: beers were accounted for; glove compartment not part of passenger area (locked; key in ignition); search unreasonable.	Denial of suppression affirmed: officers had probable cause under the automobile exception (and search-incident rationale discussed).
Did Iowa second-degree burglary qualify as a predicate "forcible felony" for AHC?	Prior out-of-state burglary conviction suffices as a predicate forcible felony.	Iowa second-degree burglary is not necessarily equivalent to Illinois burglary; State failed to prove the Iowa conviction met Illinois elements or residual clause.	Reversed AHC conviction: State failed to prove the Iowa conviction was a forcible felony under Illinois law; AHC vacated; remand for sentencing on UUWF.

United States v. Ross, 456 U.S. 798 (automobile-exception scope: search scope defined by object of search and where evidence may be found)
Arizona v. Gant, 556 U.S. 332 (limits on vehicle searches incident to arrest)
People v. Bridgewater, 235 Ill. 2d 85 (warrantless searches per se unreasonable except established exceptions)
People v. James, 163 Ill. 2d 302 (Illinois application of automobile-exception)
Quarles v. United States, 139 S. Ct. 1872 (burglary’s inherent potential for harm noted in violent-felony analysis)
Taylor v. United States, 495 U.S. 575 (rationale for categorizing burglary as violent felony)
People v. Lucas, 231 Ill. 2d 169 (State must prove every element of offense beyond a reasonable doubt)