People v. Lahr

CHIEF JUSTICE MILLER,

dissenting:

I do not agree with the majority’s conclusion that the police officer failed to effect a valid citizen’s arrest of the defendant. Accordingly, I dissent.

Section 107 — 3 of the Code of Criminal Procedure of 1963 permits “[a]ny person” to make an arrest when the person “has reasonable grounds to believe that an offense other than an ordinance violation is being committed.” (Ill. Rev. Stat. 1989, ch. 38, par. 107 — 3.) The authority granted by section 107 — 3 is available to law enforcement officers and private citizens alike. The statute does not, however, validate every extraterritorial arrest made by a police officer. Because an officer’s authority outside his jurisdiction is no greater than that possessed by a private citizen, the rule has evolved that an extraterritorial arrest is not valid under section 107 — 3 if it is based on evidence or other information the officer acquired through an exercise of official authority while outside his jurisdiction. 147 Ill. 2d at 382-83; People v. O’Connor (1988), 167 Ill. App. 3d 42, 46-47; see also United States v. Hernandez (11th Cir. 1983), 715 F.2d 548, 551; Phoenix v. State (Fla. 1984), 455 So. 2d 1024, 1025-26.

Assuming the correctness of what has been termed the “under color of office” limitation, I would not find it implicated in the present case. Here, the use of the radar device involved no assertion of official authority and provided the officer with no advantage that could not also be enjoyed by a member of the general public. That private citizens rarely use radar guns to monitor traffic, as the majority asserts in invalidating the defendant’s arrest, misconstrues the scope of the “under color of office” restriction; properly applied, that rule is triggered only by an assertion or exercise of authority, and not simply by conduct having a causal connection to- the arresting officer’s employment. In any event, I would note that the defendant in this case was traveling 80 miles per hour in a zone with a speed limit of 50, a violation that must have been apparent to even the casual observer.

The unwelcome result of today’s decision is to unnecessarily curtail the statutory authority of an officer to make an arrest outside his jurisdiction. Under the majority’s reasoning, a private citizen who uses a radar gun to detect a speeding motorist will be permitted by statute to arrest the driver, but a police officer who, outside his jurisdiction, employs the same lawful means of monitoring traffic cannot make an arrest. In these circumstances, the authority of a police officer under section 107 — 3 should be no less than that possessed by a private citizen. For the reasons stated, I respectfully dissent.