People v. Young
2025 IL App (5th) 240681-U
Ill. App. Ct.2025Background
- Khyree A. Young was stopped by Decatur police for speeding; the car he was driving had a registration expired for more than a year.
- Under city code, vehicles with registration expired over six months must be towed, so police initiated a tow and an inventory search.
- During the search, police found a magazine containing 12 rounds of 9mm ammunition in the front passenger door pocket.
- Young did not have a Firearm Owners Identification Card, a requirement to possess firearm ammunition in Illinois.
- Young filed a motion to suppress the ammunition and subsequent statements, arguing the inventory search was pretextual and unlawful.
- The circuit court denied the motion, finding the inventory search valid; Young was convicted in a stipulated bench trial and appealed the suppression ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of inventory search | Met all requirements for lawful search | Search was pretextual, not serving inventory purposes | Search valid, all three requirements met |
| Adequacy of police documentation | Documented items per policy ($50 rule) | Tow sheet insufficient, lacked detail to protect property | No minimum detail required; policy followed |
| Good faith and standard procedures | Inventory done as per standard practice | Officers' suspicions show search was investigatory/pretext | Officers acted in good faith per procedures |
| Admissibility of statements post-search | Statements followed lawful search | Statements are fruit of the poisonous tree, should be out | Search lawful, so statements admissible |
Key Cases Cited
- South Dakota v. Opperman, 428 U.S. 364 (inventory search of lawfully impounded vehicles is a recognized exception to warrant requirement)
- Colorado v. Bertine, 479 U.S. 367 (inventory search upheld provided it is done according to standardized procedures)
- Arizona v. Gant, 556 U.S. 332 (describes exceptions to the Fourth Amendment’s warrant requirement)
- People v. Hundley, 156 Ill. 2d 135 (articulates three requirements for valid vehicle inventory searches under Illinois law)
- People v. Gipson, 203 Ill. 2d 298 (describes standard for warrantless inventory searches and police procedures)