People v. Woods

2026 IL App (1st) 251214-U No. 1-25-1214 Order filed October 22, 2026 Fourth Division NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 23 CR 3083 ) VIRGINIA WOODS, ) Honorable ) Natosha Toller, Defendant-Appellant. ) Judge, presiding. JUSTICE NAVARRO delivered the judgment of the court. Justice Mitchell concurred in the judgment. Justice Ocasio dissented. ORDER ¶1 Held: The trial court did not err in denying defendant’s motion to suppress evidence where the police conducted a proper stop and search of her vehicle pursuant to Terry v. Ohio, 392 U.S. 1 (1968). ¶2 Following a bench trial, Virginia Woods was convicted of aggravated unlawful use of a weapon (AUUW) (720 ILCS 5/24-1.6(a)(1) (West 2022)) and sentenced to three years in prison. On appeal, Woods contends that the trial court erred in denying her motion to suppress evidence No. 1-25-1214 because the police violated her fourth amendment right to be free from unreasonable searches and seizures when they stopped her and searched her vehicle without a warrant, her consent, or probable cause. For the reasons that follow, we affirm. ¶3 Woods’ conviction arose from the events of September 10, 2022. Following arrest, she was charged by information with one count of AUUW and one count of unlawful use of a weapon by a felon (UUWF) (720 ILCS 5/24-1.1(a) (West 2022)). ¶4 Prior to trial, Woods filed a motion to suppress evidence. In the motion, she asserted that she had the constitutional right to “be free from unreasonable searches and seizures.” She alleged that the police unreasonably stopped, seized, searched, and arrested her in violation of this right and that, therefore, the firearm the police recovered from her vehicle should be suppressed as fruit of the poisonous tree. ¶5 At the hearing on the motion, the defense called Chicago police officer Daniel Holubik. Holubik testified that on September 10, 2022, he was on routine patrol with two partners, Timothy Blake, Jr., and A.T. Szul. About 11:52 a.m. they were dispatched to respond to a parking lot behind 7914 South Essex Avenue for “a person with a gun call.” The officers arrived at the location about two to three minutes later. There, Holubik observed “a vehicle and a female fitting the description of the dispatch call.” Specifically, he saw a dark-colored, four-door Chevrolet sedan with the driver side front door open, occupied by a woman in the driver’s seat. In court, Holubik identified Woods as the woman in the sedan. ¶6 Holubik testified that Woods “became aware of [the officers’] presence.” Through the sedan’s open driver side front door, he saw that Woods “made movements” toward the front passenger seat. The officers exited their vehicle. Due to the nature of the dispatch call and not -2- No. 1-25-1214 knowing where a firearm may have been located in the sedan, they approached cautiously and “tactically positioned” themselves around the sedan, with Holubik on the passenger side, Blake on the driver side, and Szul behind. Woods exited the sedan and spoke with Blake. The officers did not pat down or handcuff Woods when she stepped out of the sedan. ¶7 While Blake and Woods were talking, Holubik approached the passenger side of the sedan, the doors and windows of which were closed. The windows were “very tinted,” such that he could not see through them to the area “where [he] saw Woods reaching.” Holubik opened the front passenger door and observed a firearm inside an open purse on the front passenger seat. ¶8 Holubik acknowledged that he did not have an arrest or search warrant, that he had not seen Woods commit a crime, and that Woods did not give him permission to search the sedan. ¶9 On cross-examination by the State, Holubik testified that the dispatch call reported that a Black woman in a black Chevrolet had pointed a firearm at the 911 caller. He agreed that, with that information, he and his partners responded to the given location, where he observed a black Chevrolet occupied by Woods. Through the sedan’s open driver side front door, Holubik observed Woods “leaning towards the front passenger area.” Based on his experience, Holubik believed that Woods was attempting to conceal contraband. ¶ 10 Holubik and his partners exited their vehicle and approached. As Blake was speaking with Woods, Holubik opened the sedan’s front passenger side door and saw a firearm inside an open purse on the front passenger seat. In court, he explained that, based on his experience and the nature of the dispatch call, he had been concerned for his safety and the safety of his partners, and that this concern was “what led [him] to opening the front passenger door.” He stated, “I wanted to make sure the scene was safe and if there was a presence of firearms in an immediate area there.” -3- No. 1-25-1214 ¶ 11 Holubik alerted his partners to the firearm. Blake examined the other contents of the purse, which included a State identification card and debit cards with Woods’s name on them. When the officers “r[a]n her information,” they learned she did not have a firearm owner’s identification (FOID) card or a concealed carry license (CCL). ¶ 12 Holubik’s body-worn camera footage of the encounter was admitted into evidence and published in court. The video, which is included in the record and this court has reviewed, depicts Holubik exiting the passenger side of the police vehicle. As he rounds the front of the police vehicle, a parked, black, four-door Chevrolet sedan with darkly tinted windows comes into view and an officer says, “Let me see your hands.” The driver’s door of the sedan is open, and the driver’s seat is occupied by Woods, who then steps out of the sedan and speaks with the officers as they approach on foot. Eventually, an officer asks Woods to step away from the sedan and Woods complies. Holubik walks to the passenger side of the sedan and opens the front passenger door. An open purse sits on the front passenger seat. Holubik shines a flashlight on the purse with his right hand while he slightly shifts the mouth of the purse with his left hand. He says, “It’s right here” and “It’s right there” to Blake. Holubik then turns away from the vehicle and Blake handcuffs Woods. ¶ 13 In court, Holubik explained that, when he said, “It’s right here” on the video, he was referring to a firearm. He confirmed that Woods was placed into handcuffs after discovery of the firearm. ¶ 14 On redirect examination, Holubik testified that he believed the 911 caller was named Bella, but he was not sure. Holubik tried reaching Bella at the callback number that she gave the dispatcher but did not speak with her. When asked if he knew where Bella resided, Holubik -4- No. 1-25-1214 answered, “We also spoke with the [dispatcher] for their supervisor to try to get contact with the caller. We were unable to.” Holubik testified that the officers did not draw their weapons as they approached the sedan and did not handcuff Woods before he “looked inside” the sedan. Holubik maintained that he saw the firearm before he touched the purse and explained that he touched the purse for “extra confirmation” that it contained a firearm. ¶ 15 The parties argued the merits of the motion to suppress. Among other things, the State asserted that both the vehicle and Woods matched the information the police had received. The State argued, “Them asking the defendant to step away from the vehicle so that they could further investigate this very serious call that they received, this was reasonable, articulable suspicion that the defendant was armed and clearly dangerous if she’s being accused of pointing a gun at somebody.” The State maintained that the officers had probable cause “to search and recover that firearm and detain the defendant.” Woods argued that the police lacked probable cause to search the sedan where, prior to the search, “all they know is that there’s a gun in the car, and that’s not against the law.” ¶ 16 The trial court denied Woods’ motion to suppress. Reviewing the evidence, the court noted that the officers were told by dispatch that an individual matching the description of Woods, in a vehicle matching the description of the sedan, had pointed a firearm at another individual, and that the officers arrived at the scene two to three minutes later. Finding that Holubik testified credibly, the court summarized that, through the open driver side door of the sedan, Holubik saw Woods move toward the right side of the vehicle; that Woods exited her vehicle without being directed to do so; that, based on the nature of the dispatch call and Woods’ movement toward her right, Holubik opened the front passenger side door; that Holubik saw a firearm; and that Holubik -5- No. 1-25-1214 touched the purse for “extra confirmation” of what he had seen. Based on the totality of the facts and circumstances known to Holubik at the time of the search, the court found that the police had probable cause to search the sedan. ¶ 17 Subsequently, Woods proceeded to a bench trial. At trial, in addition to Holubik, officer Blake testified. Video from Blake’s body-worn camera was admitted into evidence and published in court. This court has reviewed the video. ¶ 18 The trial court found Woods guilty of AUUW and UUWF. ¶ 19 Woods filed a posttrial motion arguing, in relevant part, that the trial court erred in denying her motion to suppress evidence where the officers “did not have a warrant, probable cause or permission to search” her vehicle. At the hearing on the motion, Woods stood on the motion as it pertained to the motion to suppress evidence. The court denied the posttrial motion. In doing so, the court again reviewed its factual findings. Relevant here, the court noted that the police responded to a dispatch call of a “person with a gun” that provided a description of a vehicle and a person. When the police arrived at the location, they saw Woods, who matched the description, in a vehicle, which also matched the description. The officers saw Woods lean toward the vehicle’s front passenger seat. An officer then moved to the area where Woods had been leaning and found an open purse with a firearm in it. Based upon “all the evidence,” the court denied Woods’ motion. ¶ 20 At sentencing, the court merged the guilty findings and imposed a sentence of three years in prison for AUUW. ¶ 21 On appeal, Woods contends that the trial court erred in denying her motion to suppress evidence because the police violated her fourth amendment right to be free from unreasonable searches and seizures when they stopped her and searched her vehicle without a warrant, her -6- No. 1-25-1214 consent, or probable cause. Woods asserts that (1) the police did not have an “adequate basis” to initiate a Terry stop and that (2) the subsequent search was not supported by probable cause and therefore fell outside the “automobile exception” to the warrant requirement for a search. Woods argues that because all the evidence of her possession of a weapon was obtained through an unlawful Terry stop and an unlawful search of her vehicle, her conviction must be reversed. ¶ 22 When reviewing a trial court’s ruling on a motion to suppress evidence, we employ a two- part standard of review. People v. Holmes, 2017 IL 120407, ¶ 9. We afford great deference to the trial court’s findings of fact, which we will reverse only if they are against the manifest weight of the evidence. Id. However, we review de novo the ultimate legal ruling as to whether the evidence should be suppressed. Id. ¶ 23 As an initial matter in this case, we address the State’s assertion that Woods has forfeited her Terry claim because she did not raise the issue in her pretrial motion to suppress, at the pretrial suppression hearing, at trial, or in her posttrial motion. ¶ 24 Woods responds in her reply brief that her Terry challenge is not forfeited. She argues that she raised the issue in her pretrial motion by referring to the right to “be free from unreasonable searches and seizures,” maintains that “[t]he assertions in the written motion are enough on their own to preserve the issue for review,” and argues that the State was sufficiently apprised of the challenge to have argued at the suppression hearing that the police had a reasonable and articulable suspicion that she was armed and dangerous. In the alternative, Woods argues that, if this court finds the Terry claim forfeited, we may nevertheless reach the issue as a matter of plain error. See People v. Hardy, 2020 IL App (1st) 172485, ¶ 77 (plain error may be raised for the first time in a reply brief). -7- No. 1-25-1214 ¶ 25 The State is correct that, prior to this appeal, Woods did not cite Terry v. Ohio, 392 U.S. 1, 30 (1968), for the proposition that the police may stop a person for investigatory purposes only if reasonable, articulable facts exist to support a finding that criminal activity is afoot. However, the motion to suppress expressly alleged that Woods had a constitutional right to “be free from unreasonable searches and seizures” and that the “search and seizure in this case were not reasonable.” In addition, at the suppression hearing, defense counsel developed the factual basis upon which the trial court could consider Terry issues, such that the trial court was fully aware of the circumstances surrounding the stop. At the close of the hearing, the State argued that the police had a “reasonable, articulable suspicion that the defendant was armed and clearly dangerous.” The trial court then engaged in a Terry analysis, noting that Woods and her vehicle matched the descriptions given to the police officers by dispatch of a person who had pointed a firearm at a 911 caller, that the officers arrived at the scene two to three minutes later, and that Holubik saw Woods move toward the right in her vehicle. ¶ 26 In light of the language of the motion to suppress, the facts adduced at the hearing on the motion, the State’s argument at that hearing, and the trial court’s review of the facts surrounding the stop, we find that Woods’ Terry claim is not forfeited. See People v. Hood, 2019 IL App (1st) 162194, ¶¶ 56-59 (finding that a motion to suppress addressed a Terry issue where (1) it expressly alleged that the arrest, search, and seizure were made in violation of the defendant’s rights under the fourth amendment, (2) at the suppression hearing, counsel developed the factual basis for consideration of Terry issues, and (3) the trial court addressed the legality of the initial stop under Terry). -8- No. 1-25-1214 ¶ 27 Pursuant to Terry, a police officer may conduct a brief, investigatory stop when the officer has a reasonable, articulable suspicion of criminal activity that amounts to more than a mere “hunch.” Terry, 392 U.S. at 21-22. During a Terry stop, an officer may temporarily detain an individual for questioning where the officer reasonably believes the individual has committed, or is about to commit, a crime. Terry, 392 U.S. at 21-22; People v. Thomas, 198 Ill. 2d 103, 109 (2001). To justify the stop, the officer must be able to point to specific and articulable facts which, considered together with the rational inferences from those facts, reasonably warrant the intrusion. Thomas, 198 Ill. 2d at 109. ¶ 28 When reviewing whether a Terry stop was reasonable, this court employs an objective standard: we view the facts from the perspective of a reasonable officer at the time of the investigatory stop. Hood, 2019 IL App (1st) 162194, ¶ 62. “In assessing whether an officer had reasonable suspicion, a reviewing court must look at the totality of the circumstances of each case—an analysis that precludes the evaluation and rejection of factors in isolation from each other.” (Internal quotation marks and citations omitted.) District of Columbia v. R.W., 146 S. Ct. 1069, 1070 (2026). A reviewing court may consider evidence from both the suppression hearing and trial, and we may affirm the ruling of the trial court on any basis that is supported by the record. Hood, 2019 IL App (1st) 162194, ¶ 39. ¶ 29 Woods acknowledges that Terry stops may be based on third-party tips (see People v. Ewing, 377 Ill. App. 3d 585, 591 (2007)) and that 911 calls from victims may be considered reliable (see People v. Thornton, 2020 IL App (1st) 170753, ¶ 33). However, she asserts that “there is little reason to indulge that presumption here.” Woods argues that the call from “Bella” was effectively anonymous, which deprived the police and the court of the ability to assess her -9- No. 1-25-1214 truthfulness. Woods also argues that the caller did not report ongoing criminal activity that the police might observe, that her descriptions of the suspect and the vehicle were vague, and that there was no indication of how much time had elapsed between the incident and the call. ¶ 30 While mindful of Woods’ arguments, we find that the stop was warranted in this case based on the totality of the circumstances. Holubik’s and Blake’s testimony at the suppression hearing and trial established that they received a dispatch call of “a person with a gun.” The 911 caller had reported that a Black woman in a black, four-door Chevrolet sedan had pointed a gun at her. The officers arrived at the specific location given by the caller within two to three minutes. There, they observed Woods in the driver’s seat of a black, four-door Chevrolet sedan. While the officers were still in their vehicle, they saw Woods make “movements” or lean toward the front passenger seat of her vehicle. Based on his experience as a police officer, Holubik believed that when Woods made these movements, she was attempting to conceal contraband. See People v. Gomez, 2018 IL App (1st) 150605, ¶¶ 29-30 (where the defendant leaned toward the center of his vehicle with his hand inside his shirt and forearm covering his waist, it was reasonable for an officer, based on his experience, to reasonably suspect criminal activity was afoot). ¶ 31 We conclude that the totality of these circumstances—a 911 call from a victim of criminal activity, providing a specific location and descriptions of a person and a vehicle which were corroborated within two to three minutes, combined with Woods’ furtive movements as the police arrived on the scene—gave rise to a reasonable suspicion on the part of the officers that criminal activity had been, or was about to be, committed. See Thornton, 2020 IL App (1st) 170753, ¶ 31 (finding reasonable suspicion where “there was an initial tip from a 911 call, there was temporal proximity between the time of the tip and defendant’s location, and defendant matched the caller’s - 10 - No. 1-25-1214 description and general location”). The officers in this case were not acting on a mere hunch. The Terry stop was reasonable. ¶ 32 Woods next argues that, even if this court concludes the Terry stop was valid, the search of her vehicle, specifically, Holubik’s opening of her vehicle’s front passenger door, was unconstitutional because the police proceeded without a warrant, her consent, or probable cause. Woods asserts that the police lacked probable cause where, at the time of the search, they knew only that a 911 caller had reported that a Black woman in a dark Chevrolet had pointed a firearm at the caller, and that Woods was a Black woman in a dark Chevrolet “in the same area.” Woods maintains that probable cause is not established by “[h]appening to correspond with a vague description provided by a 911 caller who could not be located or contacted by the police.” Woods further argues that the 911 call had few indicators of reliability and lacked corroboration, and that “officer safety” was not an adequate justification for the search. ¶ 33 In this case, we need not reach Woods’ arguments regarding probable cause. This is because Holubik’s search was justified under Terry. See Hood, 2019 IL App (1st) 162194, ¶ 39 (appellate court may affirm a trial court’s ruling on a motion to suppress evidence on any basis that is supported by the record). ¶ 34 In recognition that “investigative detentions involving suspects in vehicles are especially fraught with danger to police officers,” the United States Supreme Court, in Michigan v. Long, 463 U.S. 1032, 1047, 1049 (1983), extended Terry to include “the search of the passenger compartment of an automobile” and “those areas in which a weapon may be placed or hidden.” The Long court further recognized that the safety concerns supporting such a search are not dissipated simply because the suspect is outside the vehicle, as the suspect might break away from - 11 - No. 1-25-1214 police control and retrieve a weapon from his or her vehicle, or may be permitted to reenter the vehicle before or after the conclusion of the Terry investigation. Id. at 1051-52. As such, the Long court held that an officer does not act unreasonably in taking “preventive measures” to ensure that there are no weapons within the detained individual’s “immediate grasp before permitting him to reenter his automobile.” Id. at 1051. ¶ 35 Here, a 911 caller had reported that a person matching Woods’ description, in a vehicle matching her vehicle, at the specific location where the police encountered Woods two to three minutes later, had pointed a firearm at her, and when the police arrived at the scene, they observed Woods making furtive movements toward the passenger side of her vehicle. We find that the totality of these circumstances, known to the officers at the time of the search, were such that the officers could reasonably suspect the presence of a weapon, thus implicating officer safety and justifying the search. See People v. Colyar, 2013 IL 111835, ¶¶ 40, 43 (when reviewing a Terry search of a vehicle, the reviewing court applies an objective standard to determine whether the facts available to the officer at the time of the search would lead a reasonably cautious individual in a similar situation to believe the action was appropriate). ¶ 36 We recognize that Woods was outside her vehicle at the time of the search but she was not handcuffed. As such, we cannot say that Holubik, when he opened the front passenger door of Woods’s vehicle, acted unreasonably in taking preventative measures to ensure that she did not have a weapon in her immediate control. See, e.g., People v. Jenkins, 2021 IL App (1st) 200458, ¶ 57 (where a firearm was visible to officers when they opened a vehicle’s rear doors, “even the most limited protective search under Long would yield the gun without requiring the officers to intrude on any privacy interests protected by the more stringent probable-cause requirement”); - 12 - No. 1-25-1214 People v. Johnson, 387 Ill. App. 3d 780, 784, 790 (2009) (where an officer had reasonable suspicion to believe that the suspect, who was handcuffed and secured in a police vehicle, had been involved in a shooting that had just occurred, a limited protective search of the passenger compartment of a vehicle that the officer had seen the suspect get out of was proper); People v. Norris, 2022 IL App (1st) 200375-U, ¶¶ 4-5, 28 (where the suspect made furtive movements toward his vehicle’s passenger front seat and center console while his vehicle was curbed, and then drove away when officers exited their vehicle, the subsequent Terry search of the front seats and center console while the suspect was detained outside his vehicle was warranted); Ill. S. Ct. R. 23(e)(1) (eff. June 3, 2025) (nonprecedential orders entered on or after January 1, 2021, may be cited for persuasive purposes). ¶ 37 We conclude that Holubik’s conduct in opening the front passenger door of Woods’ vehicle was a proper Terry search. As such, the recovery of the firearm from Woods’ vehicle was not the result of an unlawful search and seizure. We therefore affirm the trial court’s judgment denying Woods’ motion to suppress evidence. See Hood, 2019 IL App (1st) 162194, ¶ 39 (appellate court may affirm a trial court’s ruling on a motion to suppress evidence on any basis that is supported by the record). ¶ 38 For the reasons set forth above, we affirm the judgment of the circuit court. ¶ 39 Affirmed. ¶ 40 JUSTICE OCASIO, dissenting. ¶ 41 I respectfully dissent. The majority upholds a conviction that rests entirely on a handgun the police should never have found. Three times in the span of a few minutes, officers crossed a constitutional line. First, they seized Virginia Woods on an anonymous tip they never corroborated - 13 - No. 1-25-1214 as to any wrongdoing; second, they searched her vehicle while she stood compliant and separated from it, encircled by five armed officers; and third, they pried open her closed purse with a pen to expose a gun that was not in plain sight. Each intrusion independently violated the Fourth Amendment and article I, section 6, of the Illinois Constitution. Any one of them requires suppression. Together, they describe an investigation unmoored from the guarantees we are bound to enforce. I would vacate the judgment of the circuit court and reverse the conviction. ¶ 42 It is a cardinal principle of the U.S. and Illinois State Constitutions, that the people are not to be subjected to unreasonable searches or seizures. A Terry stop is tolerated as a narrow exception, and only when the officer can point to specific, articulable facts giving rise to a reasonable suspicion that criminal activity is afoot. When the asserted suspicion comes from an anonymous caller, the tip must carry its own indicia of reliability, for “an anonymous tip alone seldom demonstrates the informant’s basis of knowledge or veracity.” Florida v. J.L., 529 U.S. 266, 270 (2000). ¶ 43 The controlling distinction is between a tip that identifies a person and a tip that establishes wrongdoing. The Supreme Court drew that line in Florida v. J.L., 529 U.S. 266 (2000), stating that a tip must be “reliable in its assertion of illegality, not just in its tendency to identify a determinate person.” Id. at 272. An accurate description of a suspect’s “readily observable location and appearance” is reliable only in a “limited sense: It will help the police correctly identify the person whom the tipster means to accuse.” Id. Our own court has adopted this principle without reservation, repeating that the tip must be “reliable in its assertion of illegality” and that knowledge of concealed criminal activity is ordinarily shown only where the informant “accurately predicts - 14 - No. 1-25-1214 future behavior, thus indicating that the informant has ‘inside information.’ ” People v. Henderson, 2013 IL 114040, ¶ 26 (quoting Alabama v. White, 496 U.S. 325, 332 (1990)). ¶ 44 Measured against that standard, this record is barren. An untested, anonymous caller reported that a Black woman in a dark four-door Chevrolet had pointed a gun at her. Dispatch relayed a location; officers arrive in two to three minutes and found a woman and a car that matched the description. The majority treats that match as though it closed the gap. It did not. As I have said, the matching person and car, standing alone, do not verify that Woods pointed a gun at anyone. The officers confirmed Woods’s identity and nothing more. They never corroborated the only fact that made her suspicious. On this ground alone, I would reverse. ¶ 45 Even assuming a lawful stop, the search of Woods’s vehicle cannot stand. A protective sweep a passenger compartment is permissible only on “specific and articulable facts” supporting a “reasonable belief” both “that the suspect is dangerous and the suspect may gain immediate control of weapons.” Michigan v. Long, 463 U.S. 1032, 1050 (1983). Our court adopted that two- pronged test in People v. Colyar, 2013 IL 111835, a search “is permissible only when the officers possess a reasonable belief, based on specific and articulable facts and reasonable references from these facts, that the individual was dangerous and could gain control of a weapon.” People v. Colyar, 2013 IL 111835, ¶ 39. ¶ 46 The only basis the officers had to believe Woods was dangerous was the anonymous tip (allegation) that she had pointed a gun. A belief in dangerousness built on a tip too unreliable to justify the seizure is no articulable basis at all. I assert, the articulable suspicion is nonexistent; the officers corroborated only innocent identifying information from an untested anonymous caller. A sweep premised on an unreliable tip is premised on nothing. - 15 - No. 1-25-1214 ¶ 47 The majority contends that “the suspect might break away from police control and retrieve a weapon from his or her vehicle.” The idea that Woods, who is five feet four inches and weighing 240 pounds, could maneuver and outwit the officers surrounding her to retrieve a gun that may or may not be in the car is a very remote possibility. The five-to-one numerical control the officers held over a cooperative woman eliminated any genuine danger that she would break away and arm herself. The majority have substituted a recited abstraction for the articulable facts the Constitution requires. ¶ 48 Even if the stop and search were valid, opening the passenger door and purse exceeded the narrow scope of a protective search. A Terry search is not for gathering evidence; it is strictly limited to finding weapons that could harm the officer or others nearby. ¶ 49 No officer here independently observed ammunition, a weapon, or any other incriminating evidence before the purse was opened. The body-worn camera is the best evidence of what occurred. It showed Officer Holubik use what appeared to be a pen to widen the fold in the purse and a flashlight so he could see what was inside; the gun was not in plain sight. That act was itself an unauthorized search. ¶ 50 Each of these actions by the police independently requires suppression and together they leave nothing on which this conviction can stand. I would vacate the judgment of the circuit court and reverse the conviction. - 16 -