People v. West, 76 N.E.3d 60

Trooper Jarrod Johnson stopped John West on I‑80 for speeding and no seat belt; stop was video‑recorded.
During a ~14 minute stop Johnson asked numerous travel and “drug interdiction” questions, moved West to the squad car, issued a warning, returned documents, and said West was free to go.
Seconds after release, Johnson re‑engaged West, asked more questions, requested consent to search, and West twice said yes; a backup officer then arrived and the car was searched.
Officers found 16 duct‑taped bundles in vehicle doors (totaling 12,204 g); lab tested 8 bundles; field test and other evidence supported trafficking and possession charges.
West moved to suppress, arguing the stop was impermissibly prolonged and consent was involuntary; the trial court denied the motion, convicted after a bench trial, and sentenced West to 12 years plus fines.
On appeal the court affirmed suppression ruling, found the street‑value fine argument forfeited, but remanded to credit 221 days of presentence custody ($5/day) against fines.

Issue	Plaintiff's Argument (People)	Defendant's Argument (West)	Held
Whether the traffic stop was unreasonably prolonged	Stop was not unlawfully prolonged; even if some unrelated questions were asked, the stop ended when defendant was told he was free to go	Questions unrelated to traffic prolonged detention without reasonable suspicion, violating Rodriguez/Caballes principles	Affirmed: court found stop ended when documents were returned and defendant was told he was free to leave; ensuing encounter was consensual
Whether consent to search was voluntary	Consent was voluntary—defendant was told he was free and twice consented before search; State met burden to prove voluntariness	Consent was mere acquiescence to ongoing show of authority after an unlawful prolongation	Affirmed: court found consent voluntary based on totality and defendant was told he was free to go
Whether street‑value fine should be reduced	Fine based on total weight may be imposed even if not all bundles were lab‑tested	Fine should be reduced because not all bundles were tested	Forfeited: defendant failed to object at sentencing and plain‑error review did not apply
Whether defendant is entitled to presentence custody credit against fines	N/A (State conceded)	Defendant sought $5/day credit for 221 days ($1,105) toward fines	Remanded: court ordered trial court to amend sentencing order to apply $1,105 credit

Rodriguez v. United States, 575 U.S. _ (2015) (traffic stop cannot be prolonged beyond mission without reasonable suspicion)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during lawful traffic stop not Fourth Amendment violation unless it prolongs the stop)
United States v. Mendenhall, 446 U.S. 544 (1980) (reasonable person standard for seizure; Mendenhall factors)
People v. Cosby, 231 Ill. 2d 262 (2008) (traffic stop ends when paperwork returned; consensual encounters vs. seizures)
People v. Harris, 228 Ill. 2d 222 (2008) (standard for reviewing motions to suppress; when unrelated inquiries exceed scope)
People v. Brownlee, 186 Ill. 2d 501 (1999) (show of authority after return of documents can create second seizure)
Anthony v. People, 198 Ill. 2d 194 (2001) (acquiescence to authority is not voluntary consent)
People v. Nixon, 278 Ill. App. 3d 453 (1996) (street‑value fine may be based on total suspected narcotics weight)