Law School Case Brief
Heien v. North Carolina - 574 U.S. 54, 135 S. Ct. 530 (2014)
The Fourth Amendment tolerates only reasonable mistakes, and those mistakes, whether of fact or of law, must be objectively reasonable. Courts do not examine the subjective understanding of the particular officer involved. And the inquiry is not as forgiving as the one employed in the distinct context of deciding whether an officer is entitled to qualified immunity for a constitutional or statutory violation. Thus, an officer can gain no Fourth Amendment advantage through a sloppy study of the laws he is duty-bound to enforce.
Following a suspicious vehicle, Sergeant Matt Darisse noticed that only one of the vehicle's brake lights was working and pulled the driver over. While issuing a warning ticket for the broken brake light, Darisse became suspicious of the actions of the two occupants and their answers to his questions. Petitioner Nicholas Brady Heien, the car's owner, gave Darisse consent to search the vehicle. Darisse found cocaine, and Heien was arrested and charged with attempted trafficking. At trial in North Carolina state court, the trial court denied Heien's motion to suppress the seized evidence on Fourth Amendment grounds, concluding that the vehicle's faulty brake light gave Darisse reasonable suspicion to initiate the stop. The Court of Appeals of North Carolina reversed, holding that the relevant code provision, which required that a car be "equipped with a stop lamp," N.C. Gen. Stat. Ann. §20-129(g), required only a single lamp—which Heien's vehicle had—and therefore the justification for the stop was objectively unreasonable. Reversing in turn, the state supreme court held that, even assuming no violation of the state law had occurred, Darisse's mistaken understanding of the law was reasonable, and thus the stop was valid. Heien was granted a writ of certiorari.
Was Darisse's mistaken understanding of the law reasonable, thus, making the stop valid?
The Supreme Court of the United States affirmed the state supreme court's decision. The Court held that under the Fourth Amendment, reasonable suspicion could rest on a mistaken understanding of the scope of a legal prohibition. The Fourth Amendment tolerated only reasonable mistakes, and those mistakes, whether of fact or of law, had to be objectively reasonable. An officer's error of law in stopping a vehicle for a violation of N.C. Gen. Stat. § 20-129(g) because one of its two brake lights was out was objectively reasonable, thereby justifying the stop, where the statute had not previously been construed by North Carolina's appellate courts, and under the language of the statute, it was reasonable to conclude that the use of the word "other" meant that the rear lamps discussed in N.C. Gen. Stat. § 20-129(d) included brake lights.
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