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Keywords

statuteprecedenttrialmotion
trialseizure

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Heien v. North Carolina, 574 U.S. 54, 135 S.Ct. 530, 190 L.Ed.2d 475, 82 USLW 4021, 14 Cal. Daily Op. Serv. 13,829, 2014 Daily Journal D.A.R. 16,430, 25 Fla. L. Weekly Fed. S 20

Facts

On April 29, 2009, Sergeant Matt Darisse observed a Ford Escort with only one working brake light and initiated a traffic stop. During the stop, Darisse became suspicious of the occupants' behavior and obtained consent to search the vehicle, where he discovered cocaine. Heien, the vehicle's owner, was charged with attempted trafficking in cocaine after the trial court denied his motion to suppress the evidence obtained during the stop, concluding that the faulty brake light provided reasonable suspicion.

On April 29, 2009, Sergeant Matt Darisse observed a Ford Escort with only one working brake light and initiated a traffic stop.

Issue

Whether a police officer's reasonable mistake of law can provide the basis for reasonable suspicion necessary to justify a traffic stop under the Fourth Amendment.

The question presented is whether such a mistake of law can nonetheless give rise to the reasonable suspicion necessary to uphold the seizure under the Fourth Amendment.

Rule

The Fourth Amendment allows for reasonable mistakes of law to justify a stop, as long as the officer's understanding of the law is reasonable, even if mistaken.

The Fourth Amendment allows for reasonable mistakes of law to justify a stop, as long as the officer's understanding of the law is reasonable, even if mistaken.

Analysis

The North Carolina Supreme Court reasoned that Officer Darisse's interpretation of the vehicle code, which he believed required both brake lights to be functional, was reasonable. The court noted that the statute's language could lead to confusion, and since there was no clear precedent interpreting the provision, Darisse's mistake did not violate the Fourth Amendment. The court emphasized that the ultimate standard is reasonableness, not perfection.

The North Carolina Supreme Court reasoned that Officer Darisse's interpretation of the vehicle code, which he believed required both brake lights to be functional, was reasonable.

Conclusion

The Supreme Court of North Carolina affirmed the trial court's decision, concluding that the officer's reasonable mistake of law justified the traffic stop and the subsequent search.

The Supreme Court of North Carolina affirmed the trial court's decision, concluding that the officer's reasonable mistake of law justified the traffic stop and the subsequent search.

Who won?

The State prevailed in the case because the North Carolina Supreme Court found that the officer's mistake of law was reasonable, thus validating the stop and the evidence obtained.

The State prevailed in the case because the North Carolina Supreme Court found that the officer's mistake of law was reasonable, thus validating the stop and the evidence obtained.

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