Probable cause was shown for a search warrant for defendant’s house. “The complaint in Gacy did not cite to a specific crime; like this case, it was concerned with a missing person. Gacy, 103 Ill. 2d at 19-20. Since the complaint and affidavit indicated more than the defendant was the last person to see Carrie alive—also that he had her car and her debit card, and that she was not dropped off at home as he claimed—there was probable cause for the warrant.” That was nexus. People v. McVay, 2019 IL App (3d) 150821, 2019 Ill. App. LEXIS 727 (Aug. 30, 2019).
Officers had good reason to talk to defendant because he was with a woman who passed out from OD’ing in a restaurant–he needed to know what was going on. The conversation resulted in reasonable suspicion for further detention and then probable cause for a search of his car. United States v. Beverly, 2019 U.S. Dist. LEXIS 147411 (S.D. W.Va. Aug. 29, 2019).*