Heien v. North Carolina
135 S. Ct. 530
| SCOTUS | 2014Background
- On April 29, 2009, Sgt. Darisse stopped a Ford Escort on I-77 after observing a faulty right brake light.
- The occupants were Vasquez and Heien; Heien owned the car and gave consent for a search after questions about contraband.
- The stop occurred before a vehicle search revealed a bag of cocaine; both men were arrested.
- North Carolina courts diverged: appellate court held no Fourth Amendment violation; state supreme court affirmed the stop was reasonable due to a reasonable misreading of NC law.
- The U.S. Supreme Court granted certiorari to decide whether a reasonable mistake of law can supply reasonable suspicion for a stop under the Fourth Amendment.
- The Court ultimately held that a reasonable mistake of law can, under the circumstances, justify the stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a reasonable mistake of law can support reasonable suspicion | Heien contends misreading the law cannot justify a stop | State argues a reasonable legal error can sustain the stop | Yes; a reasonable mistake of law can justify reasonable suspicion |
| Whether the officer’s mistake was reasonable given the statute’s ambiguity | Heien argues the law was clear and misread by officer | State contends the statute’s ambiguity could reasonably be interpreted to require two brake lights | Yes; the mistake was reasonable and justified the stop |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (1996) (mixed question of law and fact for reasonable suspicion; not requiring perfect understanding of the law)
- Brinegar v. United States, 338 U.S. 160 (1949) (probable cause includes reasonable mistakes of both fact and law)
- DeFillippo v. Michigan, 443 U.S. 31 (1979) (recognizes probable cause despite later constitutional questions about the law)
- Illinois v. Krull, 480 U.S. 340 (1987) (exclusionary rule and evidence obtained in good faith under statutory interpretations)
- Whren v. United States, 517 U.S. 806 (1996) (subjective motivations do not render a traffic stop unlawful; focus on reasonableness of facts)
- Riddle, 5 Cranch 311 (1809) (early tolerance of reasonable mistakes of law in seizure certificates)
- The Apollon, 9 Wheat. 362 (1824) (probable cause philosophy discussed in context of legal interpretations)