People v. Haywood, 407 Ill. App. 3d 540

Police stop Haywood for activated turn signal while driving past three turn opportunities; defendant admitted his driving privileges were suspended and was arrested; search yielded heroin and led to charged offense under 720 ILCS 570/402(c).
Defendant moved to quash arrest and suppress evidence; trial court granted, ruling stop was not justified at inception; State appealed.
Facts established Deputy Lillge observed blinking turn signal and stopped defendant; defendant acknowledged lack of license due to suspension; officer cited Traffic Code violations for driving with a suspended license and improper use of a turn signal; a search incident to arrest produced evidence supporting the charged offense.
Trial court relied on McDonald (7th Cir.) as controlling on faulty application of 11-804(d) and held no good-faith exception saved the stop; court rejected Sorrells-based justification for stopping for minor or alternative reasons.
On appeal, court reviews suppression order de novo for legal ruling, with factual findings given deference; key issue is whether the stop was justified at inception or based on a mistaken belief of a traffic violation; analysis considers both 11-804(d) and equipment-based Vehicle Code provisions; State forfeited an equipment-malfunction theory raised for the first time on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop justified at inception under 11-804(d)?	People urged that defendant violated 11-804(d) by activating the turn signal and passing opportunities to turn.	Haywood contends no violation of 11-804(d) occurred; turning past opportunities with a signal is not prohibited by the plain meaning.	No; 11-804(d) does not prohibit activating a turn signal and passing opportunities; stop unjustified at inception.
Could Vehicle Code equipment provisions (12-208, 12-212, 12-101) justify the stop?	State argued equipment provisions prohibit flashing lights used as a signal in the manner observed.	Haywood argued those provisions regulate equipment, not use; statute language and structure show different domains.	No; these provisions govern equipment, not use; they do not justify the stop at inception.
Does the officer's mistaken belief of a traffic violation justify the stop (McDonald-style good faith)?	State maintained mistake of law could justify stop.	Haywood argued officer’s belief was not legally grounded because no violation occurred.	No; officer’s mistake of law cannot justify the stop; stop not objectively reasonable.
Did the State preserve its malfunctioning turn signal argument for appeal?			The State forfeited this argument for failure to raise below.

People v. Close, () (Fourth Amendment seizure review of stops with deference to trial court factual findings)
People v. Cosby, 231 Ill.2d 262 (2008) (de novo review of suppression rulings; standard framework for suppression)
People v. Luedemann, 222 Ill.2d 530 (2006) (two-step standard for reviewing suppression; factual deferential, legal de novo)
People v. Davison, 233 Ill.2d 30 (2009) (statutory interpretation; use of plain meaning; ambiguity analysis)
People v. Donoho, 204 Ill.2d 159 (2003) (statutory interpretation—plain meaning and legislative intent)
McDonald v. United States, 453 F.3d 958 (7th Cir. 2006) (police mistake of law cannot support probable cause or justify stops)
People v. Mott, 389 Ill.App.3d 539 (2009) (mistake-of-law stops; reliance on other bases for stop possible)
People v. Cole, 369 Ill.App.3d 960 (2007) (reasonable suspicion analysis; dual motivations in stops)
People v. Sorrells, 209 Ill.App.3d 1064 (1991) (warning can occur without violation; other justification for stopping)
Griffin v. Illinois Bell Tel. Co., (1962) (discussion on flashing lights; dicta cited regarding negligence context)
United States v. Miller, () (Texas analog; interpretation of signaling provisions)