People v. Sparks

In People v. Sparks, 315 Ill. App. 3d 786, 734 N.E.2d 216, 248 Ill. Dec. 508 (2000), the police arrested the two defendants for drug-related offenses after a search of their vehicle uncovered cannabis. Police conducted a Terry stop of the vehicle based solely upon a tip from a confidential source that the two defendants would be traveling Interstate 55 south with contraband in the car. The source, a known police informant, gave the police the defendants' names, their races, their ages, a detailed description of the vehicle, and the approximate time they would be traveling through the area. A surveillance team was positioned on the interstate at the expected time, and upon spotting the vehicle, they initiated a stop. The officers asked both of the defendants if they could search the vehicle, but they refused. Canine units arrived within minutes, performed a sniff of the vehicle, and alerted to the trunk of the car, where the drugs were found. Sparks, 315 Ill. App. 3d at 788-89, 734 N.E.2d at 218-19. In Sparks, the officers relied solely on the "innocent details" provided by the informant, without attempting to corroborate those details in any way