See People v. Adams, 161 Ill. 2d 333, 344-45 (1994) (evidence that individuals were seen exiting an airline bathroom where contraband was found was sufficient circumstantial evidence to support conviction of unlawful possession of a controlled substance); see also People v. McLaurin, 331 Ill. App. 3d 498, 503 (2002) (hiding drugs to avoid detection indicates an intent to exercise control over them). Defendant relies upon People v. Ray, 232 Ill. App. 3d 459 (1992), People v. Blackman, 62 Ill. App. 3d 726 (1978), and People v. Jones, 105 Ill. App. 3d 1143 (1982), in support of his arguments that he did not have exclusive control over the truck where the drugs were found and that his mere proximity to the contraband was insufficient to establish constructive possession. In Ray, the reviewing court reversed a defendant's conviction of possession of cocaine as a result of the State's failure to show that the defendant owned, rented, or lived in the apartment where the cocaine was found.

Such a fact is significant because the Illinois Supreme Court has held that the usual requirement of prior reliability which must be met when police act upon "tips" from professional informers does not apply to information supplied by ordinary citizens. People v. Hester (1968), 39 Ill.2d 489, 237 N.E.2d 466; People v. Hammers (1976), 35 Ill. App.3d 498, 341 N.E.2d 471; People v. Blackman (1978), 62 Ill. App.3d 726, 728-29, 379 N.E.2d 344, 346, holding: "Under Aguilar and its progeny, hearsay information from an informant may be considered as the basis for a search if the investigating officer is aware of some facts indicating that the informant is reliable and some facts indicating that the informant ascertained his information in a reliable manner.

The Curry court reasoned that "[the] defendant did not have control over the premises, the automobile." Id. at 73. In People v. Blackman, 62 Ill.App.3d 726, 730-31 (1978), the Third District reversed two automobile passengers' convictions of possession of cannabis, where there was no evidence that the passengers had any control over the automobile in which the cannabis was found, and the State conceded that the passengers were not in constructive possession of the cannabis. Significantly, however, the cannabis was locked in the vehicle's trunk, and only the driver had the key. Id.

The defendants respond that under pre- Gates Illinois law, the presumptively reliable status of a citizen informer does not attach to a citizen who does not identify himself. (Compare People v. Davis (1980), 86 Ill. App.3d 557, 407 N.E.2d 1109, with People v. Townsend (1980), 90 Ill. App.3d 1089, 414 N.E.2d 483; People v. Sylvester (1980), 86 Ill. App.3d 186, 407 N.E.2d 1002; People v. Mitchell (1979), 68 Ill. App.3d 370, 386 N.E.2d 153; People v. Kahl (1978), 63 Ill. App.3d 703, 380 N.E.2d 487; People v. Blackman (1978), 62 Ill. App.3d 726, 379 N.E.2d 344.) In People v. Martin (1977), 46 Ill. App.3d 943, 950, 361 N.E.2d 595, 600, the court quoted the following explanation for that rule.

In the present case the defendants do not contest the sufficiency of the underlying circumstances showing why Hogan's conclusions were believable because she stated that her information was based on personal observation. ( People v. Blackman (1978), 62 Ill. App.3d 726, 379 N.E.2d 344.) The issue is whether the affidavit contained sufficient underlying circumstances for the magistrate to decide whether Hogan was reliable.

Such a procedure falls short of that required by the fourth amendment. Citing People v. Blackman (1978), 62 Ill. App.3d 726, 379 N.E.2d 344, the State argues that the credibility of an anonymous citizen informant (as opposed to a paid police informer) may be presumed. In People v. Davenport (1974), 19 Ill. App.3d 426, 428, 311 N.E.2d 751, this court held invalid a complaint for search warrant which set out the following facts:

No issue is raised as to validity of the search warrant itself, as the doctrine of collateral estoppel ( People v. Hopkins (1972), 52 Ill.2d 1, 4, 284 N.E.2d 283, 284) precluded the trial court in St. Clair County, and precludes us, from addressing that issue. • 1-3 The totality of the circumstances presented to the investigating officers at the time of the search must be considered to determine whether a warrantless search was justified ( People v. Blitz (1977), 68 Ill.2d 287, 369 N.E.2d 1238; People v. Blackman (1978), 62 Ill. App.3d 726, 379 N.E.2d 344). If it was otherwise justified, the legitimacy or scope of the search warrant used by police is immaterial. ( People v. George (1971), 49 Ill.2d 372, 274 N.E.2d 26.) Similarly, where probable cause for a warrantless arrest existed, the arrest is not invalidated because made pursuant to a warrant later found to be invalid. ( Giordenello v. United States (1958), 357 U.S. 480, 488, 2 L.Ed.2d 1503, 1510-11, 78 S.Ct. 1245, 1251; United States v. Rabinowitz (1950), 339 U.S. 56, 60, 94 L.Ed.2d 653, 657, 70 S.Ct. 430, 432.

• 1 As phrased by the defendant, the first issue is whether the defendant "was not proven guilty beyond a reasonable doubt where the State's evidence only established a possibility as to defendant's possession of L.S.D. and where the testimony of the State's chief witness was substantially impeached." This court has previously noted that although the defendant's possession may be a reasonable assumption, a conviction can not be supported by assumption, conjecture or speculation ( People v. Boswell (1974), 19 Ill. App.3d 619, 312 N.E.2d 17), for in deciding questions of guilt the courts do not deal in probabilities, but require proof beyond a reasonable doubt ( People v. Blackman (1978), 62 Ill. App.3d 726, 379 N.E.2d 344). In People v. Jackson (1961), 23 Ill.2d 360, 178 N.E.2d 320, the defendant was found guilty of the unlawful possession of narcotic drugs.