the traffic stop was not a lawful traffic stop because the turn signal is just video evidence shows in this case because government exhibit one not to mention that was a finding by the district court and that's at appendix page one  on when he moved from the driving lane traffic lane that is into the parking lane and that's one of the actually no lanes anyway and this largely deserted road parallel of the lane where mr stanbridge was driving there was space to park vehicles and so that is considered a park of lanes far as i understand illinois law and because my client used his turn signal he complied with illinois law when he pulled over and your point i thought i mean looking at this illinois statute it uses the word appropriate a couple of times in terms of describing the need to s as i understand your argument there's no hundred foot rule before you pull over to park there is not and there's nothing the statute says that there is rather there is a one hundred foot requirement in the event that you are making a term which is commonly understood to that's the hundred foot requirement but that isn't required here when there's not a turn there was a lane change a lane change required you to signal which mike and i were neither did the right we are and there can be or not but there's no way this can be see stop or suddenly decrease that's where one of the places where this word appropriate appropriate shows up at the final sentence of a inappropriate shows up in c d doesn't say anything it just says you have to use your signal if you're going to change lanes it is never been argued that c would apply i don't think the facts as demonstrated by the video would suggest that it does and indeed the officer thought that the lane change itself required the one hundred foot continuous turn signal requirement which he was clearly wrong but many that see was never a basis for anybody's determination so i don't think that is really in the ambit of today's case but so what about a different way of looking at this case you've got the two officers sitting there as i understand it in the front seat of their car and one of them sees him fail to signal when he makes a left turn which is certainly something covered by b he doesn't signal the other one doesn't see him why doesn't collective knowledge apply to justify the later traffic stop i point out first of all that that alleged failure to signal was never recorded and so we have one officer and that officer never provided that information to the other officer and i guess i'm asking you how important is that and maybe the government  waived this site i'm not saying that this is necessarily a good theory but just the collective knowledge back to require the officer who sees the illegal left turn to see mention of the other officer all look you know he just turned without signaling i believe it does and we cited a case for that proposition any of that i think waiver is a political leader the government has argued that the district court clearly determined that the collective knowledge doctrine did not save the government's process on that particular point and it stated so not as directly perhaps as we may wish but there was but one determination for probable cause and that was the alleged illegal lane change but again under eleven eight  my client satisfied with the relevant statute was he used his turn signal before he changed lane you had it on simultaneously so the provision that was clickable was satisfied and there was no probable cause for the officers to make the stop me i just for what it's worth i read the district court's opinion the same way she goes through the left turn now civs comments that hodges didn't say anything to bangor and then she moves on to say officer bangor did however see standridge pulled to the right in curve so i think that's the transition we're saying well forget about that first theory and i thought it was clear enough it wasn't clear to the government but my reading is the same  your honor and that brings us i think to that high an issue which the district court delved into and i believe made the determination incorrectly that the government hasn't argued high in this case and so we have another wave of problem that the government has not attempted to defend the district court's application supreme court decision high end and i think that it would be difficult if not impossible to defend the application of high end here given that we have separate sketch to requirements for turn signals where there's a l change in a term that has a separate signaling requirement and very clearly my client was under the requirements of the sub provision be and not be so the one hundred foot rule doesn't apply and the officers should know the traffic laws better than anybody in this case and they thought that there was a one hundred foot requirement that is an unreasonable mistake of law because the law clearly does not have the one hundred foot requirement for lane changes it's hard for me to believe that the officers thought that and there's i mean i realize this twenty is not chicago but if there were a hundred foot requirement for parking in chicago people would just go around with their blinkers on all the time because you never know when that parking place is going to pop up i would hate to be in a state court judge who's deciding traffic ticket cases i don't know when you can leave the courthouse clearly cannot be the way the government has asserted it the way that the officers are saying that it applies it simply is an unreasonable mistake of longer rely on this court's flor decision and then lastly we hope not to get to the rodriguez issue we would think that it's clear enough that the decision was wrong the evidence should have been suppressed but because the district court went into out righ as if there is something that required this case to get reminded we should have the opportunity to develop morning jason bomb we have the government mr hillis and mr bond you really think that you have to signal a hundred feet before you pull into a parallel parking place i think if you did if illinois one hundred feet your honor no i think before is the key in that sentence you have to signal before you do something the whole point is i watched the video he did signal before he it's hard for me to tell on the video though i think the thirty four fold one in it shows his turn signal on he's still in the traffic lane he's not he's not at the at the curb so it sure looks like it's before and there's nobody on the road i mean you know it's not like this is some rush hour down in quincy it's you know what's true and but the traffic laws apply whether or not there's a car on the road or not the stop sign i he says start from a you must you must you must use yours you know signal if you start from a parallel park position it doesn't say when you park lanes out there and you're changing from one to the other when you decide to park whether it's you know angle parking or whether it's parallel parking i'm not sure that  covers that particularly since it does cover the opposite situation when you start for the parallel park exception i believe we all agree to that subsection would apply whenever you it's no you said you were talking about d d and somehow you seem to use it no it's true the term parking lane is occasionally roos but changing lanes people don't think that parking is changing lanes changing lanes as you're driving along and you change lanes or maybe a car behind right parking is a different animal if there are for example if there are no part cars on the side of the road then you're brevity i think our point is twofold one of what you're getting at is what we believe that the law does require a signalling before you change well where do you see that in d i think when it says you need to indicate an intention to turn that you need to indicate the intention to turn prior to making the turn and turning i don't mean a ninety degree but i mean a but look you've got two different you've got to look you have intention to turn change lanes or start from a parallel park position those are three different things if they meant to her to be seen when you when you park right then they would need to and then they would need to say start from a parallel park as they say if you park you have to signal and that's not when anyone would understand to be turning or changing lanes let alone starting from parked position i take your point and i'm i'm not here to say that this is the most finely crafted illinois statute i don't know i think it's fine i think you just misinterpreting that you know the wrong and that might be just doesn't cover parking that might be but the desert that's what it is it doesn't cover parking in my case i think that the illinois law does require a signal prior to park it doesn't  i think i understand that you might believe we're misinterpreting it but i believe the district court was correct in finding that the officers interpretation was reasonable that the illinois traffic laws require a signal in order to help so you think that the police department would sell tell the officers that the means you've got a signal when you park they do that not that i'm aware of your honor and i would like to address  judge would something you brought up earlier and mr stanbridge has argued in his reply brief that we mischaracterize that evidence and i wouldn't that's a serious allegation and when i read judge miers coffs last sentence of her introductory paragraph that says because stamp urges improperly signaled turns gave police probable cause to initiate a traffic stop his motion should be denied then her traffic violations she uses the plural turns and she uses the plural violations to me that's a clear indication that she's finding probable cause was based on plural more than one well but the problem is then you go on and read the rest of the opinion where she is saying on page seven that stanbridge is time was in violation of eleven eight zero four thereby providing probable cause for officer to initiate the traffic stop that then she goes on to take it back she says officer hodges however was not driving the police car and did not initiate the traffic stop officer bangor as the driver did and then she goes on to the part that i was just cussing with mr hillis so i think whether she used the plural of the header or not she considers it she doesn't think that's enough she action in the district court you don't see that developed she might have wanted to think about it but it's just not there so whether that would have supported or not i don't think is properly here we i believe it is the following reason i think the object the analysis of whether a fourth amendment is violated as an objective analysis officer hodges was must be as much the arresting officer as officer banger it's factually there's no question really undeveloped in the district court's opinion i mean there are there's a mine of cases about collective knowledge and it usually assumes that officer is a communicate something to be but you don't worry that he didn't observe it because they did i think they all work as a team that's true collective knowledge is completely undeveloped in the appellate some brief as well and why would he want to develop it he's saying that if the grat the actual ground that she relied on is flawed he doesn't want to support the government's position i think if you if if what you're finding is that officer or i'm sure that judge maurice coughed didn't find probable cause for officer hodges observations i think your opinion is crystal clear and that is not what officer hodges just means you didn't argue it wouldn't develop a rule for anything we don't base precedent on waived arguments i think the what we relied certainly on officer hodges observation probable cause before the district court there's no question about that it's in our seems to reject it though and i don't think that's clear especially when she uses the plural because of his improper turns and violations otherwise if officer hodges had been the one who flipped the switch and he didn't that would support probable cause in this case but because officer banger is the one who flipped the switch it does not and i don't think that is a reasonable interpretation of the fourth amendment i think if there is objective probable cause and here there's no question that the left hand turn was on signal and thirteen seconds later there was a traffic stop officer hodges shouldn't be under some rule where he has to say did you see the left hand turn is that why you're right and i wasn't saying that but anyway you need to wrap up because you prosecute for the you know for the traffic violation record whether or not a person could be prosecuted from an i believe is a different i don't think you could the short answer the longer answer is i think whether a person could ultimately be prosecuted for it is different than if the officer have a reasonable interpretation of that can't be right you can't convict a person for violating a law that he has violated just because a police officer erroneously believes he violated the no you can't that's correct you can't convict somebody proof beyond a reasonable doubt is different than whether the officer had a reasonable belief penalties don't know what the law is they aren't told what it is they're given i believe that's what happened in hind in your honor i believe that's what happened in hind in the supreme court case where he was arrested for that but ultimately that was not going to support a conviction but the court nevertheless that it was a reasonable interpretation that's what judge myers cough found here and we think that is correct thank you all right thank you very much anything further  we are course on the appeal left the record as it comes and there are certain findings that were made and there were certain findings that weren't there arguments that were developed in their arguments that weren't and the government cannot argue heinen now when it didn't argument argue in its  f and it can't say that the district court its opinion which i think was fairly clear quite clear about the one determination that did make about probable cause is correct because even if the  either in the context of a lane change if this is lane change or if it was parking the turn signal was on what is definite is a turn signal does not have to be on for one hundred feet as the officer thought that it did that is an unreasonable mistake of law in short the traffic stop was bad resulting evidence is free to the poisonous tree and the district court erroneous lee decided not to suppress the evidence we asked this court to make that finding thank you all right thank you very much thanks to both counsel