M. Massa

It was unreasonable for the officer to conduct an investigatory stop when he responded to a report that a woman was trapped under her car, but the woman had freed herself prior to his arrival, and the officer witnessed no traffic infractions or criminal conduct.

Police officer had reasonable basis to believe that medical assistance was needed or defendant was in danger so that warrantless entry into vehicle was constitutionally permissible.

The imposition of a sentence of life without parole was reversible error by the trial court because the sole aggravating factor supporting the sentence was not determined by the trier of fact beyond a reasonable doubt during the penalty phase. The Supreme Court concurred with defendant’s initial request, and in the interests of judicial economy, exercised their appellate prerogative and resentenced him to a total term of 88 years.

The legislature intended a sentence of life imprisonment without possibility of parole to fit within the definition of a “term of imprisonment” and when imposing such a sentence the trial court must make certain specific findings.