IL: Officer staying on porch after completion of business was unauthorized, and def couldn’t be conviction of obstruction after that

Defendant’s obstructing a peace officer conviction had to be reversed because, while an officer could initially enter defendant’s porch, once he found no evidence of a crime, staying there was an unauthorized act which defendant could lawfully obstruct. People v. Jones, 2015 IL App (2d) 130387, 2015 Ill. App. LEXIS 176 (March 17, 2015).

Defendant was arrested for drugs, and that justified a search of his backpack in the car. In the backpack were medical records in a notebook. The officer leafed through the notebook looking for drugs, so he said, and the trial court credited that. In the notebook, multiple names and social security numbers were found, and that led to defendant being charged with aggravated identity theft and wire fraud. The numbers were in “plain view” considering the looking at the notebook was reasonable under the circumstances. United States v. Reeves, 2015 U.S. App. LEXIS 4339 (11th Cir. March 18, 2015).