People v. Tramble, 980 N.E.2d 1254

Defendant Odell P. Tramble charged with unlawful possession of ammunition by a felon (720 ILCS 5/24-1.1(a)).
Pretrial motions to suppress evidence were denied by the trial court which found no lawful grounds for the stop.
State argues the officers had probable cause under 11-804(a) to stop defendant’s vehicle.
During testimony, dispute over whether defendant pulled onto a shoulder or stopped within his lane without signaling.
A K-9 unit alerted to contraband and ammunition was found in the trunk after a vehicle search.
Appellate Court reversed and remanded to resolve disputed facts and apply the statute’s interpretation to determine legality of the stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 11-804(a) requires signaling before moving onto the shoulder	State argues signaling is required for the shoulder move.	Tramble contends the court misread the statute and may not require a signal for the movement.	Statute requires a signal for moves including leaving the roadway; remand for factual findings.
Whether the stop was justified under 11-804(a) given disputed facts	State asserts sufficient grounds existed to stop the vehicle.	Tramble asserts no lawful basis for the stop given lack of signaling and positioning.	Remanded to resolve factual disputes and apply statute interpretation.
Whether suppression was proper based on the trial court’s interpretation	State contends suppression was improper if stop was valid.	Tramble argues the suppression was correct due to improper stop.	Reversed and remanded for further proceedings consistent with decision.

People v. Absher, 242 Ill. 2d 77 (2011) (two-step suppression analysis; factual findings reviewed for weight)
Whren v. United States, 517 U.S. 806 (1996) (temporary traffic-stop seizure requires reasonable suspicion)
People v. Hackett, 2012 IL 111781 (2012) (standards for traffic-stop justification and suppression reviewed)