State v. Antonio D. Brown, 850 N.W.2d 66

State sought review of a court of appeals decision reversing the circuit court’s denial of Brown’s motion to vacate his conviction and guilty plea and to suppress evidence from a vehicle stop.
Court of appeals held there was no probable cause or reasonable suspicion to stop Brown; evidence from the stop should be suppressed.
State argued Wis. Stat. § 347.13(1) requires all tail-lamp bulbs lit, so the unlit bulb justified the stop and could support reasonable suspicion.
Court interpreted § 347.13(1) to require a tail lamp to emit a red light visible from 500 feet, not every bulb lit; related § 347.06 confirms condition requirements.
Since the stop rested on an unlit bulb and no violation of § 347.13(1) was shown, there was no lawful basis for the stop or the subsequent search; the evidence must be suppressed.
The majority affirmed the court of appeals; Brown’s alternative ineffective-assistance and sentencing-credit arguments were not addressed due to reversal on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 347.13(1) requires all tail-lamp bulbs to be lit.	Brown: tail lamp bulbs must all be lit to be in good working order.	State: unlit bulb can render lamp not in good working order; stop warranted.	Stop invalid; unlit bulb alone does not establish violation.
Whether an officer’s mistake of law can justify a stop.	Brown: mistake of law cannot justify a stop.	State: mistake of law could support a stop if reasonable under totality.	Majority holds mistake of law cannot justify stop; stop invalid; evidence suppressed.
Whether the evidence from the stop should be suppressed as fruit of an unlawful seizure.	Brown: stop was unlawful; suppress all evidence.	State: stop valid; evidence admissible.	Evidence suppressed; stop unconstitutional.
Whether the search was permissible under the good-faith/exceptions analysis.

Popke v. State, 317 Wis. 2d 118 (2009 WI 37) (probable cause/reasonable suspicion standard for traffic stops; constitutional review)
Whren v. United States, 517 U.S. 806 (1996) (preeminent rule: traffic stops must be reasonable)
Longcore v. State, 226 Wis. 2d 1 (Ct. App. 1999) (mistake of law generally cannot sustain a stop)
State v. Eason, 245 Wis. 2d 206 (2001 WI 98) (exclusionary rule and good-faith/applied doctrine)
Dearborn v. State, 327 Wis. 2d 252 (2010 WI 84) (exclusionary-rule exceptions for reliance on settled law)
Delfin-Colina, 464 F.3d 392 (3d Cir. 2006) (mistake of law as basis for stop may be reasonable under totality)
Chanthasouxat v. United States, 342 F.3d 1271 (11th Cir. 2003) (mistake of law/fact in stop determinations)
McDonald v. State, 453 F.3d 958 (7th Cir. 2006) (stop based on reasonable belief of violation; mistake of law not always fatal)
Heien v. North Carolina, 737 S.E.2d 351 (N.C. 2012) (recognized as relevant to reasonable belief despite ambiguity)