Can Police Stop a Car It There Is Reason to Believe That the Driver Subject of An Arrest Warrant ?

In People v. Safunwa, 299 Ill. App. 3d 707, 233 Ill. Dec. 928, 701 N.E.2d 1202 (1998) the court concluded that officers had a justifiable basis for making the traffic stop where they reasonably believed that the driver of the car they stopped was the subject of an arrest warrant. In support of its conclusion, the court held that sufficient probability, rather than certainty, is the touchstone of reasonableness under the fourth amendment. The court noted parenthetically in the citation that "when officers have probable cause to arrest one party and they reasonably mistake a second party for the first party, then arrest of the second party is valid for purposes of fourth amendment search and seizure analysis." Safunwa, 299 Ill. App. 3d at 711.