On December 15, 2014, the Supreme Court of the United States issued an opinion that held a police officer’s reasonable mistake of law gives rise to reasonable suspicion that justifies a traffic stop. The events that gave rise to the case of Heien v. North Carolina originated on April 29, 2009 near Dobson, North Carolina.
On that morning, Sergeant Matt Darisse of the Surry County Sheriff’s Department noticed and followed a vehicle that only had one brake light working. He then pulled the driver over and issued a warning ticket for the broken brake light. While issuing the ticket, Sergeant Darisse became suspicious of the actions of two occupants and their answers to his questions. After obtaining consent to search the vehicle from the vehicle’s owner, Sergeant Darisse found cocaine and Mr. Heien was arrested and charged with attempted trafficking.
At trial, Mr. Heien made a motion to suppress the evidence that alleged that Sergeant Darisse violated the Fourth Amendment. Nonetheless, the trial court denied Mr. Heien’s motion, concluding that the vehicle’s single faulty brake light gave Sergeant Darisse reasonable suspicion to initiate the stop. The North Carolina Court of Appeals reversed, holding that the relevant code provision only required a single brake lamp – which Mr. Heien’s vehicle had – and therefore Sergeant Darisse’s justification for the stop was justifiably unreasonable. The North Carolina Supreme Court held, assuming that no violation of the state law occurred, Sergeant Darisse’s mistaken understanding of the law was reasonable, and therefore valid.
When the case reached the highest Court of the land, the Supreme Court of the United States agreed with North Carolina’s high court. The Court began its analysis by noting that it had repeatedly affirmed, “the ultimate touchstone of the Fourth Amendment is ‘reasonableness.’ ” The Court also cited Brinegar v. United States noting that the Fourth Amendment requires government officials to act reasonably, not perfectly, and gives those officials “fair leeway for enforcing the law.”
The Court also cited Michigan v. DeFillippo, where it held that an arrest was supported by probable cause even though the statute that justified the rest was later held unconstitutional. In that case the search of the defendant produced illegal drugs. The defendant argued that the results of the search should be suppressed because the arrest was based on an unconstitutional statute. The Court in DeFillippo, however examined the purpose of the exclusionary rule, which is to deter police misconduct. Since there was no evidence of such misconduct, the Court in DeFillippo held that the evidence of drugs should not have been suppressed. Here, in Heien v. North Carolina, the Court applied the same concept that it did in DeFillippo and opposed Mr. Heien’s argument that if police officers are given such leeway, then they will have an incentive to be oblivious to the law.
Ultimately, the Supreme Court reached its holding due to the uncertainty of meaning in the North Carolina vehicle code. It requires “a stop lamp” and also proves that the lamp “may be incorporated into a unit with one or more other rear lamps.” N.C. Gen. Stat. § 20-129(g). The vehicle code also requires that “all originally equipped rear lamps” must be “in good working order.” N.C. Gen. Stat. § 20-19(d). The United States Supreme Court noted that although the North Carolina Court of Appeals held that “rear lamps” do not include brake lights, the word “other,” along with the lack of state-court precedent interpreting the specific vehicle code provision at issue, made it objectively reasonable to thing that a faulty brake light constituted a violation of statute.
Moving forward, it seems that since the North Carolina Court of Appeals has interpreted the brake light statute, a traffic stop by law enforcement officers resulting from one faulty brake light would not be objectively reasonable. Learn Your Rights 101.