People v. Evans

The State appeals the order of the circuit court of McHenry County suppressing as evidence cocaine seized from the briefcase of defendant, Joseph M. Evans. The State contends that the police officer’s warrantless search of the briefcase was justified as (a) an inventory search of a detainee, (b) a search incident to arrest, and (c) a consent search. Because we believe the cocaine was seized pursuant to a valid inventory search, we reverse and remand.

On November 4, 1997, Algonquin police officers stopped the Cadillac defendant was driving and arrested him for driving on a suspended license.…