State v. Heien
366 N.C. 271
N.C.2012Background
- Officer stopped a vehicle for a non-functioning brake light based on observed malfunction; brake-light evidence raised suspicion of contraband; defendant and driver were traveling together with conflicting destination statements; search was conducted after consent from the driver and defendant; cocaine was found in a bag during the search; defendant moved to suppress as illegal stop under Fourth Amendment and NC Constitution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a stop based on a reasonable but mistaken belief about the law can be supported by reasonable suspicion | State argued mistake of law can support reasonable suspicion | Defendant argued no violation of statute, stop invalid | Yes; mistake of law reasonably interpreted can justify stop under totality of circumstances |
| Whether officer’s reasonable mistake of law should be treated differently from facts-based mistakes in Fourth Amendment analysis | Majority allows reasonable mistake of law to justify stop | Dissent argues no room for mistake of law in reasonable suspicion | Court adopts rule that reasonable mistakes of law may give rise to reasonable suspicion |
| Whether the Court of Appeals properly interpreted NC brake-light statutes for purposes of the stop | Court of Appeals erred in requiring multiple functioning brake lights | Statutory interpretation not dispositive if totality shows reasonable suspicion | We assume one brake light rule and uphold stop based on reasonable suspicion |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable suspicion grounded in totality of the circumstances)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (stop based on observed violation is constitutionally valid when probable cause exists)
- State v. Barnard, 362 N.C. 244, 658 S.E.2d 643 (N.C. 2008) (objective facts; officer’s motive irrelevant to stop's legality)
- State v. Ivey, 360 N.C. 562, 633 S.E.2d 459 (N.C. 2006) (precedent evaluating stops where no statutory violation found)
- United States v. Chanthasouxat, 342 F.3d 1271 (11th Cir. 2003) (mistake of law cannot provide reasonable suspicion; but reasonable interpretation may)