Motion to suppress evidence; Probable cause; Illinois v Gates; Good-faith exception to the exclusionary rule; People v Goldston

In an order in lieu of granting leave to appeal, the court reversed the Court of Appeals judgment (see eJournal # 83614 in the 5/14/25 edition), holding that the trial court erred in denying defendant’s motion to suppress. The court agreed with the Court of Appeals dissent that the search-warrant affidavit did not “connect the firearms and firearm-related items listed in the search warrant with the suspected criminal activity. Therefore, there was not probable cause to believe ‘that contraband or evidence of a crime will be found in a particular place.’” It also agreed with the Court of Appeals dissent that “the affidavit was so lacking in indicia of probable cause that reliance on it was objectively unreasonable. There were no allegations that the defendant used a firearm to commit a crime. Therefore, the good-faith exception to the exclusionary rule did not apply . . . .” The court remanded the case to the trial court.