Bradford, J.
Following a traffic stop, during which law enforcement discovered contraband, Parnell Dion Lanier was charged with Level 5 felony unlawful carrying of a handgun, Level 5 felony possession of cocaine, and Class A misdemeanor possession of marijuana. Lanier moved to suppress certain evidence, namely the contraband that had been recovered from his person and his vehicle during the traffic stop. The trial court denied Lanier’s motion to suppress and, at Lanier’s request, certified the case for interlocutory appeal.
Lanier contends that the trial court erred in denying his motion to suppress the challenged evidence, arguing that the evidence should have been suppressed because the initial traffic stop was unlawful. For its part, the State argues that the traffic stop was lawful and the search was reasonable. We affirm.
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Prior to January 1, 2023, Indiana Code section 9-21-8-25 read, in relevant part, that “[a] signal of intention to turn right or left shall be given continuously during not less than the last two hundred (200) feet traveled by a vehicle before turning or changing lanes.” As Lanier acknowledges, Indiana Code section 9-21-8-25 did not include any limitation of where or when use of a turn signal was required. It is undisputed, however, that Indiana Code section 9-21-8-25 was repealed effective January 1, 2023.
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The parties focus their arguments relating to Indiana Code section 9-21-8-24 to subsection (a)(2), which provides that “[a] person may not … turn a vehicle from a direct course upon a highway” without using a turn signal to inform others of the intended turn. Lanier reads Indiana Code section 9-21-8-24(a)(2) narrowly, arguing that the phrase “upon a highway” indicates that the vehicle in question was already on the public highway and would not include a vehicle turning onto the public highway from a private drive. For its part, the State reads Indiana Code section 9-21-8-24(a)(2) more broadly, arguing that the phrase “upon a highway” includes movement taking a driver on-to the highway. While Lanier and the State both argue that their interpretation is the correct interpretation that should be applied to Lanier’s case, we find support for both interpretations in Webster’s Third New International Dictionary (Unabridged), which includes the following definitions for the word “upon”: “in or into close proximity or contact with by way of” and “on the surface … on it[.]” WEBSTER’S THIRD NEW INTERNATIONAL DICTIONARY 2517, 2518 (Phillip Babcock Gove et al. eds., G. & C. Merriam Company 1966). We need not choose between the parties’ differing interpretations of the meaning of the phrase “upon a highway,” however, because even assuming that Lanier’s more limited interpretation was the interpretation intended by the Indiana General Assembly at the time the statute was written, we conclude that Officer Poynter’s alleged mistake of the law was reasonable under the Fourth Amendment.
Indiana Code section 9-21-8-24(a)(3) requires use of a signal if a person intends to “change from one (1) traffic lane to another; unless the movement can be made with reasonable safety.” Indiana Code section 9-21-8-24(a)(3) does not contain the limiting phrase “upon a highway” that is present in Indiana Code section 9-21-8-24(a)(2). Pointing to Indiana Code section 9-21-8-24(a)(3), the State argues that the term “‘traffic lane’ is not defined in the traffic laws, and it would have been a reasonable belief that the lane of exit and entry of a busy business like a gas station would constitute a ‘traffic lane[.]’”
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We conclude that to the extent that Officer Poynter may have relied on a mistake of law when he initiated the traffic stop, any mistake of the law was reasonable under Heien. Again, “[t]o be reasonable is not to be perfect, and so the Fourth Amendment allows for some mistakes on the part of government officials, giving them ‘fair leeway for enforcing the law in the community’s protection.’” Heien, 574 U.S. at 60–61 (quoting Brinegar, 338 U.S. at 176). Further, while judges and attorneys interpret the words and phrases contained in a criminal statute to determine the statute’s intended meaning, police officers are neither trained nor required to consider all possible interpretations but must rely on a common-sense understanding of the law before making an on-the-spot determination as to what conduct is prohibited. Where, as here, multiple meanings of a particular word or phrase in a statute are possible, when reviewing police action, the question must be whether the officer’s on-the-spot determination was reasonable. Because Officer Poynter could have reasonably believed that Lanier’s conduct was prohibited by Indiana Code section 9-21-824, through either subsection (a)(2), (a)(3), or both, any mistake in the law was reasonable. The traffic stop, therefore, did not violate the Fourth Amendment.
Lanier also argues that the search was unlawful under Article 1, Section 11. When considering whether a search is lawful under Article 1, Section 11, we consider “each case on its own facts to decide whether the police behavior was reasonable.” Brown v. State, 653 N.E.2d 77, 79 (Ind. 1995). Again, in Litchfield, the Indiana Supreme Court recognized that while “there may well be other relevant considerations under the circumstances,” the reasonableness of a search turns “on a balance of: 1) the degree of concern, suspicion, or knowledge that a violation has occurred, 2) the degree of intrusion the method of the search or seizure imposes on the citizen’s ordinary activities, and 3) the extent of law enforcement needs.” 824 N.E.2d at 361.
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We further agree that “a blanket ban on evidence recovered as a result of a reasonable mistake of law goes against the letter and spirit of Article 1, Section 11” and the reasonableness of an alleged mistake of law should be considered on a case-by-case basis. Id. As such, we adopt the analysis of the United States Supreme Court in Heien and believe that the question of whether an alleged mistake of law is reasonable under Article 1, Section 11, requires a determination of whether the alleged mistake of the law is reasonable under Litchfield.
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Moreover, for the reasons stated above, we find that any mistake in the law by Officer Poynter with regard to whether Lanier had been required to use his turn signal was reasonable given the requirement in Indiana Code section 9-21-824(a)(2) and (a)(3) that a driver use his turn signal when turning from a direct course upon a highway or changing from one traffic lane to another. Again, effective January 1, 2023, the statute was amended to encompass all qualifying situations, not just those when another driver may be impacted, which could lead one to reasonably infer that the statute applied to situations like the one at issue in this case.
In sum, to the extent that Officer Poynter’s belief that he had observed a traffic infraction may have been a mistake of law, we conclude that any mistake of the law by Officer Poynter was reasonable under both the Fourth Amendment and Article 1, Section 11. As such, the traffic stop did not violate either constitutional provision. The trial court, therefore, did not err in denying Lanier’s motion to suppress the challenged evidence.
The judgment of the trial court is affirmed.
Kenworthy, J., and Felix, J., concur.