28 N.E.3d 293
Ind. Ct. App.2015Background
- Police officer observed Williams’ passenger-side taillight with a large hole emitting significant white light while the vehicle moved forward.
- Officer Packard believed any white light emitting from the rear while the vehicle is moving forward violated Indiana law and stopped the vehicle.
- Search after the stop discovered marijuana; Williams was convicted of Class A misdemeanor possession.
- This court initially reversed the conviction, reasoning a mistaken belief about what constitutes an infraction cannot support reasonable suspicion for a traffic stop.
- The State petitioned for rehearing, relying on the U.S. Supreme Court’s decision in Heien v. North Carolina (reasonable mistakes of law can support reasonable suspicion if objectively reasonable).
- On rehearing, the court concluded Officer Packard’s legal mistake was objectively reasonable under Heien and therefore affirmed the trial court’s judgment (denying suppression).
Issues
| Issue | State's Argument | Williams' Argument | Held |
|---|---|---|---|
| Whether a traffic stop based on an officer’s mistaken belief that a vehicle infraction occurred can be justified where the mistake is of law | Heien permits reasonable mistakes of law to supply reasonable suspicion; Officer Packard’s belief was objectively reasonable given the taillight’s appearance and statutory language | A mistake about what the statute prohibits cannot constitute good-faith justification for a stop; the statute does not prohibit white light from emitting | The court held Heien controls: the officer’s mistake of law was objectively reasonable, so the stop was supported by reasonable suspicion and the evidence need not be suppressed |
Key Cases Cited
- Heien v. North Carolina, 135 S. Ct. 530 (2014) (Supreme Court: reasonable mistakes of law can supply reasonable suspicion if the mistake is objectively reasonable)
- Williams v. State, 22 N.E.3d 730 (Ind. Ct. App. 2014) (prior panel opinion reversing conviction before rehearing)
- Ransom v. State, 741 N.E.2d 419 (Ind. Ct. App. 2000) (discussed regarding prior rule that officer’s mistaken belief about statutory violations does not amount to good faith)