IL: No RS for stop of van allegedly involved in a robbery; officer had no details

“The trial court decided the facts were sufficient to justify a Terry stop. After taking account of the totality of the circumstances, we reverse the denial of Maxfield’s motion to quash arrest and suppress the identification and other evidence obtained, vacate the convictions for armed robbery and unlawful use of a weapon, and remand for a new trial. We do so because without any distinctive or individualized details, the officer lacked a reasonable, articulable suspicion to stop an individual who happened to be walking in a general area. As the Supreme Court recognized in Terry, a stop should not ‘be undertaken lightly.’ Id. at 17.” People v. Maxfield, 2023 IL App (1st) 151965-B, 2023 Ill. App. LEXIS 326 (Sep. 15, 2023).*

CI’s tip was corroborated by defendant’s late night trip to a closed McDonald’s, and that was reasonable suspicion. United States v. Helton, 2023 U.S. App. LEXIS 24372 (6th Cir. Sep. 12, 2023).*

There was probable cause for the warrant for the [redacted] place in the warrant. The good faith exception also applies. The Franks challenge fails for lack of materiality to probable cause. United States v. Obryant, 2023 U.S. Dist. LEXIS 161875 (N.D. Cal. Sep. 5, 2023).*

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