United States v. LeShawn Stanbridge, 813 F.3d 1032

Stanbridge was convicted of possession with intent to distribute methamphetamine under 21 U.S.C. § 841(a)(1) after drugs were found in his duffle bag following a traffic stop.
Police detained Stanbridge in Quincy, Illinois, for allegedly failing to signal continuously for 100 feet before pulling to the curb to park.
Dashcam video confirms Stanbridge did not signal for 100 feet before parking; officers disagreed on whether a left turn without signaling occurred.
The district court denied suppression, relying on Officer Bangert’s belief that signaling 100 feet was required, despite it being arguably mistaken.
Stanbridge entered a conditional guilty plea while preserving the suppression issue; he was sentenced to 144 months' imprisonment.
On appeal, the court held that the mistake of law was not reasonable and that the suppression motion should have been granted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the 100-foot signaling rule §11-804(b) applicable to parking at the curb?	Stanbridge: statute not require 100 feet for curb parking.	Bangert: signaling distance applies to turns, including curb parking as a turning movement.	Statute not ambiguous; 100-foot rule applies to turns, not curb parking; officer's misreading not reasonable.
Was the stop supported by reasonable suspicion given the officer's belief about the signaling requirement?	Stanbridge's stop cannot rely on an unambiguous misreading of §11-804.	Bangert's reasonable belief, even if mistaken, could justify the stop under Heien.	Officer Bangert's mistake of law was not objectively reasonable; cannot justify the seizure.
Did the district court properly rely on Hodges's left-turn observation to justify the stop?	Left-turn basis was not accepted by the district court as a standalone justification; not challenged on appeal.	Government argued Hodges's observation provided alternative basis for seizure.	Waiver or failure to challenge the district court’s rejection of the left-turn basis; the basis was not preserved.
Did Stanbridge ultimately prevail on the suppression issue?	Statute does not require 100 feet; stop based on unreasonable misreading should be suppressed.	Government argued for waiver and alternative justification; not ultimately persuasive.	Stanbridge prevailed; suppression should have been granted; conviction vacated and remanded.

Heien v. North Carolina, 135 S. Ct. 530 (2014) (police may rely on reasonable, though mistaken, interpretations of ambiguous laws)
United States v. Flores, 798 F.3d 645 (7th Cir. 2015) (police cannot rely on sloppy readings of statutes to gain Fourth Amendment advantage)
United States v. Cherry, 436 F.3d 769 (7th Cir. 2006) (government waiver considerations in suppression appeals)
United States v. Wilson, 390 F.3d 1003 (7th Cir. 2004) (waiver when government fails to challenge district court’s determinations)
United States v. Dyer, 580 F.3d 386 (6th Cir. 2009) (waiver and appellate review limitations in Fourth Amendment challenges)
United States v. Dachman, 743 F.3d 254 (7th Cir. 2014) (defendant standing and suppression rulings on review)
Fryer v. United States, 243 F.3d 1004 (7th Cir. 2001) (forfeiture principles in suppression context)