United States v. Lawrence
675 F. App'x 1
1st Cir.2017Background
- On June 21, 2013 Detective Michael Reynolds observed a sedan on a two-lane road in Braintree whose right wheels crossed the white fog line by ~2 feet as it passed his cruiser.
- Reynolds ran the plate, learned the car was registered to another person, and—recalling a tip linking Lawrence to a vehicle at that address—stopped the vehicle believing the crossing violated Mass. Gen. Laws ch. 89, § 4A (marked lanes statute).
- The stop led to searches that uncovered 21 small bags of crack cocaine; Lawrence moved to suppress the evidence as the traffic stop was unlawful.
- The district court denied suppression, concluding that even if the law on fog-line crossings was unclear, the officer’s belief that a violation occurred was an objectively reasonable mistake of law under Heien v. North Carolina.
- Lawrence appealed solely arguing: crossing a fog line does not violate § 4A absent evidence the crossing was unsafe and no reasonable officer could conclude otherwise.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an officer could reasonably believe crossing a fog line by ~2 feet violated Mass. Gen. Laws ch. 89, § 4A | Government: crossing the fog line meant the vehicle was not "entirely within a single lane," so § 4A was violated | Lawrence: § 4A requires unsafe lane changes; innocuous crossings of the fog line do not violate the statute | Court: Affirmed stop — under the statute and Massachusetts authority the question is ambiguous and the officer’s mistake was objectively reasonable under Heien |
Key Cases Cited
- Heien v. North Carolina, 135 S. Ct. 530 (2014) (an objectively reasonable mistake of law can justify a stop)
- United States v. Dubose, 579 F.3d 117 (1st Cir. 2009) (standard of review for suppression rulings)
- United States v. Arnott, 758 F.3d 40 (1st Cir. 2014) (traffic violation as reasonable basis for stop)
- United States v. Jenkins, 680 F.3d 101 (1st Cir. 2012) (reasonable suspicion standard for traffic stops)
- United States v. Monteiro, 447 F.3d 39 (1st Cir. 2006) (totality of the circumstances test for reasonable suspicion)
- Whren v. United States, 517 U.S. 806 (1996) (objective reasonableness inquiry for traffic stops disregards officer’s subjective motives)