City of East Grand Rapids v. Trevor Allen Vanderhart, 329259

Background

Early morning Jan 5, 2014, Officer Lobbezoo observed defendant’s car and believed one rear taillight was out; on following, he saw the passenger-side taillight was significantly dimmer than the driver-side and stopped the vehicle.
On approach officer smelled alcohol, observed glassy/red eyes, administered field sobriety tests, arrested defendant for OWI; breath tests later showed BACs of 0.14 and 0.13.
Defendant moved to suppress evidence, arguing the stop lacked reasonable suspicion because both taillights were visible from 500 feet (complying with MCL 257.686); district judge Jordan denied suppression, finding the dim taillight gave reasonable suspicion and posed a safety concern.
At trial a different judge (Servaas) later granted defendant’s renewed suppression motion, finding the dash-cam showed taillights visible from 500 feet and suppressing the evidence; the prosecution appealed to circuit court.
The circuit court vacated the trial judge’s ruling, reinstated the conviction, reasoning the officer’s belief was a reasonable mistake of law under Heien and/or the dim taillight created an unsafe condition under MCL 257.683.
On appeal to the Court of Appeals, the panel affirmed: (1) Judge Servaas’s factual finding that both taillights were visible from 500 feet was clearly erroneous; (2) Heien did not justify a stop under §686 because the statute is not ambiguous; but (3) the stop was justified under §683’s general prohibition on operating a vehicle in an unsafe condition given the significant brightness disparity and hazardous conditions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was supported by reasonable suspicion under MCL 257.686 (taillight visibility requirement)	Officer’s observation of a significantly dim taillight justified inspection/stop	Both taillights were plainly visible from 500 feet, so no §686 violation and no reasonable suspicion	Court: §686 requires taillight to emit red light plainly visible from 500 feet; record does not show a §686 violation and the trial judge’s finding that both taillights were visible from 500 feet was clearly erroneous
Whether Heien (reasonable mistake of law) shields the stop if officer misinterpreted §686	Officer’s mistake about the law was reasonable under Heien, so evidence should not be suppressed	§686 is not ambiguous; reasonable-mistake-of-law doctrine does not apply here	Court: Heien does not save the stop—§686 unambiguous as read in context, so a mistake of law would not be objectively reasonable
Whether the stop was justified under MCL 257.683 (vehicle in unsafe condition)	Dim passenger taillight created an unsafe condition (other drivers might think defendant was braking), justifying the stop	No unsafe-condition violation where equipment met §686’s visible-from-500-feet standard	Court: Stop was justified under §683 because the taillight disparity, dark/winter/icy conditions, and congested area created reasonable suspicion of an unsafe condition
Whether suppression was the proper remedy for the Fourth Amendment claim	Exclusion required if stop unlawful	Evidence derived from lawful stop should not be suppressed	Court: Suppression was improper because the stop was supported by reasonable suspicion under §683; conviction reinstated

Key Cases Cited

Heien v. North Carolina, 574 U.S. 54 (United States Supreme Court) (reasonable-suspicion may be based on an objectively reasonable mistake of law)
Whren v. United States, 517 U.S. 806 (United States Supreme Court) (stop’s reasonableness judged objectively, independent of officer’s subjective motives)
Mapp v. Ohio, 367 U.S. 643 (United States Supreme Court) (exclusionary rule for unlawfully obtained evidence)
People v. Williams, 236 Mich. App. 610 (Michigan Ct. App. 1999) (vehicles with multiple taillights must have all taillamps operative)
People v. Johnson, 466 Mich. 491 (Michigan Supreme Court) (standard for clear-error review of suppression findings)