People v. Bell

In February 2009, the State charged defendant, John E. Bell, with two counts of child pornography (720 ILCS 5/11 — 20.1(a)(6) (West 2008)) based on images found on his computer’s hard drive. In May 2009, defendant filed a motion to suppress physical evidence, arguing the search and seizure of his computer was conducted without lawful authority. Following a November 2009 hearing, the trial court granted defendant’s motion.

The State appeals, arguing (1) police had actual and apparent authority to search defendant’s computer based on the consent given by defendant’s then-girlfriend, (2) the…