United States v. Charles Bowers, 678 F. App'x 460

On May 28, 2014, Officer Mark Fitzgerald stopped Charles Bowers’ car because a taillight, when lit, emitted both white and red light.
During a consensual search, the officer found baggies containing cocaine base and marijuana; Bowers was indicted for possession with intent to distribute.
Bowers moved to suppress the drugs, arguing the traffic stop lacked lawful basis because Missouri Rev. Stat. § 307.075 does not prohibit any white light from a taillight.
Officer Fitzgerald testified he believed any white light from a taillight violated § 307.075, which requires rear lamps to exhibit a red light plainly visible from 500 feet.
The magistrate judge and district court found the officer’s interpretation objectively reasonable and denied the suppression motion; Bowers conditionally pleaded guilty and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was lawful	Bowers: § 307.075 requires only that taillights in operable condition exhibit a red light plainly visible up to 500 ft; some white light that does not overpower red does not violate the statute	Government: § 307.075 can reasonably be read to prohibit defects including a taillight that emits any white light; officer’s understanding was reasonable	Held: Stop lawful — officer’s objectively reasonable (though mistaken) view of the statute justified the stop under Heien

Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable mistake of law can supply reasonable suspicion for a stop)
United States v. Williams, 777 F.3d 1013 (8th Cir.) (standard of review for suppression rulings)
United States v. Gaffney, 789 F.3d 866 (8th Cir.) (application of Heien in this circuit)
United States v. Walker, 840 F.3d 477 (8th Cir.) (traffic violation provides probable cause to stop when officer has objectively reasonable basis)
Kienzle v. Dir. of Revenue, 944 S.W.2d 326 (Mo. Ct. App.) (construing a taillight with white light as an apparent violation of § 307.075)