People v. Patel

The issue presented in this case is whether a passenger in an automobile detained pursuant to a routine traffic stop is entitled to Miranda warnings where the passenger is questioned regarding suspected unlawful activity unrelated to the basis for the stop. The State appeals from the trial court’s order granting the motion to suppress statements of defendant, Samir R Patel. For the reasons that follow, we affirm.

Defendant was charged by traffic citation with the unlawful consumption of alcohol by a minor. 235 ILCS 5/6 — 20 (West 1996). Defendant filed a motion to suppress the statements he…