and the task force could have on their own conducted the fourth amendment intrusions here however they did not and were forced forced to focus on the objective facts and information available to you have to concede that not every individual officer involved in the arrest or the search has to know all the details your honor i agree as a general matter i would take issue specifically factually we don't concede that the police department as a whole had probably cause to pull over the vehicle and i would like to highlight that one i'm sorry i may have misspoken you concede that somebody in the this was a suspect in an aggravated robbery i provide the identity identifying information for the physical description as well as the vehicle that that person was driving and then the officer actually made a stop a terry stop based upon that communication here sergeant meyer asked for a traffic stop and that is the term of art within law enforcement and i would like to emphasize that several officers sergeant meyer stated was traffic stop in this is that you are ninety nine officer lawrence said it was a traffic stop it you are twenty seven an officer holden recognized it's a request for a traffic stop and that's precisely what he did he followed the vehicle for one half mile approximately as you stated and then observateur whether if he concluded that it that he committed lane straddle in violation he stopped it on that basis then when he asked for the driver's license only because it was a mexican driver's license or foreign driver's license he arrested him based upon not having california driver's license now the government has never argued in any of its pleadings that the arrest was valid based states versus that isn't that correct under california law your honor based upon the l a superior court appellate decision is assuming that is california law yes that the conjunction of of failing to remain as practical within the lanes and failing to ensure that you're not obstructing the flow of traffic assuming that that was correct and we adopting of the reasoning of collins that would be permissible however in iran or even assuming that was a valid stop the search for the canine sniff of the vehicle was based upon was a direct result of the unlawful arrest in this case of mr belcher and based upon the license and so the government can get around the unlawful arrest by relying on the main trail and i would point out that the judge did not find it on that basis and the governor has government has never argued that is an alternative gro vehicle on the side of the road that has no devival it is not a situation of what you find yourself in and given that is the case why can't they bring a dog along the cart i'm going anywhere heat we do not fault officers for making a mistake a fact so people should be incorrect in finding that the vehicle actually traversed the dotted and botched lines then at the end of the day it will be upheld product of an unreasonably prolong traffic stop this would warrant suppression and that's a spring court relying on another illinois supreme court decision here if there is no there's no way for the government to argue that the lane straddling caused the vehicle to be there for longer than an hour the only reason it was fair it's because he was arrested and taken from the scene the government can't now of bail themselves out of a mistake of law which we concluded can never sported a basis for arrest and then say well now that the vehicle is there we can conduct this dog sniffed if you could have never been there have officer hovan never relied on a mistake of law to cart your honor we're not under run reaches united states pretext doesn't matter we look to the objective facts known to the officer at the time tearing out the traffic stop and here the only information that he had was that was links rattling and then s license and he was in error the key to your argument is that the label traffic stop defines what's going on as well as the legal ramifications your honor that is part of a traffic to label traffic stop it is but here we just look objective we added actions in what officer holden did if you believe it all that this was a probable cause stop he would have could have simply just pulled over the vehicle at that time and carried out investigation based upon a suspected drug activity but that's not what he did if meyer had told him we want this guy the same question you heard earlier get  your position is that would have been a valid stop your honor not to simply get him would have been sufficient but get him for drug activity see well be effective for drug activity yes your honor in and i would just like to highlight that in newman the decision this is a district court decision after serving all of its courts president the standard some minimal level of information regarding probable cause for the government to invoke collective knowledge which purpose is being served by this distinction and if you made the concession that there's probable cause which you did right in the very beginning to have stopped him for that are  purpose here is your honor if it's critical for several reasons that the communication requirement apply and first is the supreme court standard articulated regarding what is necessary for  this is an exception to the warrant requirement we allow officers to articulate specific facts and any conclusions drawn therefrom known at the time to determine whether the stop was reasonable in your honor the only way we get that link where this court can objectively evaluate whether that was reasonable is providing this minimum level of communication it certainly does not for law enforcement in any way for officer or sergeant meyer to staple this vehicle over for drug activity and your honor the fact that he said traffic stop negated any and left it at a minimum and bigamous officer hoban what what what officer safety reasons you are assuming that's the case that was not what was relayed to you officer holding right but it wasn't related yes your honor but even assuming that that was the true i have probable cause to believe that the vehicles involved in drug activity that would have been sufficient around or it would have taken a few notes are white wine is sufficient obviously hold it doesn't know any of the probable cause and the request for a traffic stop which was clearly preceded by officer hold and that means develop your own independent basis relying on the vehicle code to stop it changes the occupants big government knows now under rand that pretext is ok that when they don't have probable cause or reason suspicion they can come up they can rely on the vehicle code to stop and develop additional information as long as the original basis and that could have i disagree that the only way to interpret op charging myers request is that we have probable cause to detain us vehicle based on drug activity it's not a way it certainly isn't way but that is elevating the subjective suspicions of officer hovan over his objective knowledge and actions in this case and even if we could if it was permissible which it's not under ran to look subjectively at what officer haldeman thought the ulterior motive was for the stop that's not what he ever said in his third statement which was provided after the hearing he simply states