Reasonable Mistake of Law Still Gives Reasonable Suspicion
This week, in an 8-1 decision, the U.S. Supreme Court ruled that the Fourth Amendment is not violated when a police officer makes a traffic stop based on a reasonable but mistaken understanding that the driver is breaking a traffic law.
In Heien v. North Carolina, the High Court held that because a police officer’s mistake of law was reasonable, there was reasonable suspicion to justify the traffic stop under the Fourth Amendment. The opinion was released on Dec. 15, 2014.
The Court emphasized that the Fourth Amendment prohibits unreasonable searches and seizures. With this case, the officer’s belief that the Defendant’s broken brake light was illegal was a reasonable mistake. Therefore, both the traffic stop that followed and also the search that was consented to were also reasonable.
Here’s what happened. A police officer followed a suspicious car. After noticing only a single brake light was working, he pulled the vehicle over. While writing a warning ticket for the broken light, the officer became very suspicious of the individuals inside. The car owner gave the officer consent to do a search of the car. In turn, the officer found cocaine. The car owner was then arrested and faced a charge of attempted drug trafficking.
The trial court denied the defendant’s motion to suppress the seized evidence. Concluding that the broken brake light gave the officer reasonable suspicion to make the traffic stop, it found no Fourth Amendment violation.
However, the Court of Appeals reversed, because state law only required that a car be “equipped with a stop lamp”. In other words, a single tail light was sufficient under the law, which made the traffic stop unreasonable. This is an uncommon situation where the language of the statute was unclear. Most traffic laws tend to be clear and straightforward.
The State Supreme Court then reversed the lower court’s decision, holding that even if it was assumed that no state law was violated, the police officer’s mistaken knowledge of state law was reasonable. Therefore, this was still a valid traffic stop. Then the U.S. Supreme Court affirmed the decision.
The defendant was not appealing a brake light ticket. He was appealing a cocaine trafficking conviction, where there were no asserted mistakes of law or fact. So while the officer could not provide a brake light ticket on a mistaken understanding of the law, reasonable mistakes in law are enough to make an investigatory stop. These are separate issues here. When it comes to whether or not an officer violates a citizen’s Fourth Amendment rights, there is an expectation of reasonable but not perfect conduct.
If you have a concern that your Fourth Amendment rights have been violated, speak up! The attorneys of The Kronzek Firm PLC are here to help you.