People v. Clark

Illinois Supreme Court
Criminal Court
Warrantless Arrest
Citation
Case Number: 
2024 IL 127838
Decision Date: 
Thursday, December 19, 2024
Holding: 
Judgments affirmed.
Justice: 
OVERSTREET

Defendant was found guilty, under an accountability theory, of two counts of aggravated battery with a firearm and ultimately was sentenced to an aggregate of 32 years in prison. The appellate court affirmed defendant’s conviction and sentence and the supreme court granted defendant’s petition for leave to appeal. Defendant argued on appeal that the investigative alert system used by the Chicago Police Department, which served as probable cause for the defendant’s arrest, was unconstitutional and that the trial court erred when it denied his motion to quash arrest and suppress evidence. The supreme court affirmed, finding that state case law has “long recognized” the validity of warrantless arrests based on probable cause and that defendant’s arrest was not unconstitutional. The court also found no error in defendant’s sentencing. (THEIS, HOLDER WHITE, CUNNINGHAM, ROCHFORD, and O’BRIEN, concurring and NEVILLE, dissenting)