In People v. Oliver, 387 Ill. App. 3d 1045, 901 N.E.2d 482, 327 Ill. Dec. 154 (2009), the defendant, a driver, was stopped for following another vehicle too closely. Oliver, 387 Ill. App. 3d at 1046. Because the defendant did not have a valid driver's license, the officer asked Orlando James, a passenger in the car, whether his driving privileges were intact. In response, James verbally gave the officer his identification. The officer's dispatcher advised the officer that, although James was on mandatory supervised release, his driving privileges were not impaired. The officer then told the defendant and James that they were free to go as long as James drove. However, because a strong odor emanating from inside the car aroused the officer's suspicions, the officer asked the defendant and James whether he could search the car. The defendant and James consented to a search of the car's interior, which uncovered a liquor bottle that smelled like the odor the officer detected. The officer then asked the defendant and James whether he could search the trunk of the car. Both men consented. That search uncovered cocaine. Oliver, 387 Ill. App. 3d at 1047. The defendant moved to suppress the evidence, and the trial court denied the motion, finding that the officer did not illegally detain the defendant and James before requesting consent to search. Oliver, 387 Ill. App. 3d at 1049. The trial court then determined that the men voluntarily consented to the search of the car. Oliver, 387 Ill. App. 3d at 1049. On appeal, the reviewing court considered "whether [the officer's] request for consent to search the trunk constituted a new seizure of the defendant." Oliver, 387 Ill. App. 3d at 1051. The court found that it did, noting that a reasonable person in the position of the defendant or James would not have felt free to leave when the officer asked for consent to search the trunk. Oliver, 387 Ill. App. 3d at 1051. And, because the officer lacked reasonable and articulable suspicion of criminal activity when he asked for consent to search the trunk, the appellate court concluded that the new seizure of the defendant and James was unlawful. Oliver, 387 Ill. App. 3d at 1052.