370 P.3d 1130
Ariz. Ct. App.2016Background
- Deputies smelled burnt marijuana near Stoll in a convenience store; when he and a passenger left in an SUV deputies followed and stopped the vehicle a block or two away.
- Deputies observed white light from the license-plate lamp visible from the rear; the lamp was standard, functioning properly, and rendered the plate legible. No citation was issued for the lamp.
- During the stop deputies detected signs of intoxication; Stoll later registered .165 on a breath test and was arrested for aggravated DUI while his license was suspended/canceled/revoked.
- At the suppression hearing the deputies testified they believed white light visible from the rear violated A.R.S. § 28-931(C); the trial court initially granted Stoll’s motion to suppress, finding no statutory violation or safety concern.
- After the U.S. Supreme Court’s decision in Heien, the State moved for reconsideration arguing the officers made a reasonable mistake of law; the trial court granted reconsideration, found the mistake objectively reasonable, denied suppression, and Stoll was convicted following a bench trial.
- The Court of Appeals vacated the conviction, holding § 28-931(C) regulates lamp color (not direction/trajectory of light), the officers’ statutory interpretation was objectively unreasonable under Heien, and the stop lacked reasonable suspicion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 28-931(C) prohibited a license-plate lamp from emitting any white light rearward | Stoll: statute unambiguously regulates color; license-plate lamp emitting white light to the plate is expressly permitted | State: statute ambiguous; difference between “illuminating” and “emitted” allows reading that any rear-directed white light (not just reflected on plate) violates § 28-931(C) | Held: § 28-931(C) governs lamp color, not light direction; lamp complied with law and did not violate § 28-931(C) |
| Whether the officers’ mistake of law was objectively reasonable under Heien | Stoll: statute unambiguous, mistake unreasonable; suppression required | State: under Heien, reasonable mistakes of law can justify stops; deputies’ training and language differences in the statute made the mistake reasonable | Held: Mistake was objectively unreasonable; training or department interpretation does not save an incorrect reading; stop lacked reasonable suspicion |
| Whether suppression denial on reconsideration was proper | Stoll: trial court erred in vacating suppression because mistake was unreasonable | State: court properly applied Heien and found objective reasonableness | Held: Trial court abused discretion in granting reconsideration; suppression should have been reinstated |
| Remedy | Stoll: conviction should be vacated and case remanded | State: conviction should stand because stop was justified by reasonable mistake of law | Held: Conviction and sentence vacated; case remanded for further proceedings |
Key Cases Cited
- Heien v. North Carolina, 574 U.S. 54 (Sup. Ct. 2014) (Fourth Amendment tolerates objectively reasonable mistakes of law for reasonable-suspicion stops)
- State v. Moreno, 236 Ariz. 347 (Ariz. Ct. App. 2014) (review standards for suppression rulings)
- Dobson v. McClennen, 238 Ariz. 389 (Ariz. 2015) (statutory interpretation reviewed de novo; legislative intent controlling)
- State v. Teagle, 217 Ariz. 17 (Ariz. Ct. App. 2007) (articulable reasonable suspicion standard for investigatory stops)
- State v. Patterson, 97 P.3d 479 (Idaho Ct. App. 2004) (similar statutory language held to regulate lamp color)
- Williams v. State, 853 P.2d 537 (Alaska Ct. App. 1993) (taillight color regulation supports color-focused statutory reading)
- United States v. Flores, 798 F.3d 645 (7th Cir. 2015) (rejecting overbroad interpretations that would justify widespread stops)
- United States v. Stanbridge, 813 F.3d 1032 (7th Cir. 2016) (Heien does not excuse misinterpretation of an unambiguous statute)