IL: State showed reasonable belief in common authority for consent

The state established reasonable belief in common authority of defendant’s wife over his micro-SD card where there was child pornography. To rebut the state’s consent case, defendant would have to show that she actually had limited authority over the card, and he didn’t. People v. Baker, 2021 IL App (3d) 190618, 2021 Ill. App. LEXIS 453 (Aug. 20, 2021).

“The Government presented sufficient evidence to show that Officer O’Neil had probable cause to believe that Kinloch had committed traffic violations. That probable cause was sufficient to justify both the initial stop and the subsequent arrest, despite any dispute about whether officers also had probable cause to believe Kinloch was driving under the influence of an intoxicant. Kinloch’s behavior after he was stopped created reasonable suspicion sufficient to justify a pat down.” United States v. Kinloch, 2021 U.S. Dist. LEXIS 158079 (S.D.Ga. July 27, 2021).*

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