United States v. Milton Henry, 853 F.3d 754

Baton Rouge officers stopped Milton Henry after observing a license-plate frame that obscured the expiration date on his registration sticker.
On contact, an officer detected a strong odor of marijuana; Henry admitted to having a marijuana blunt and consented to a vehicle search.
The search yielded two bags of marijuana, a digital scale, and a loaded handgun; Henry acknowledged ownership of the drugs and scale; the gun was claimed by his wife.
Henry’s wife consented to a subsequent home search, producing more marijuana, a bag of cocaine, and paraphernalia.
Henry was indicted for possession of a firearm by a felon (18 U.S.C. § 922(g)(1)) and possession of marijuana (21 U.S.C. § 844(a)); he moved to suppress evidence from the traffic stop.
The district court denied suppression, and after a bench trial Henry was convicted; he appealed, arguing the stop lacked reasonable suspicion because the officers’ interpretation of Louisiana statute § 32:53(A)(3) (regarding license-plate legibility) was incorrect.

Issue	Henry's Argument	Government's Argument	Held
Whether the traffic stop was justified at inception	Officers lacked reasonable suspicion because § 32:53(A)(3) does not prohibit obscuring a registration sticker with a frame	The statute forbids foreign materials obscuring a plate or attached sticker; officers reasonably believed a violation occurred	Stop was justified: officers’ interpretation was objectively reasonable
Whether a mistake of law can support reasonable suspicion	Mistake of law here is unreasonable because statute applies only to plate characters	Even a legal mistake can justify a stop if objectively reasonable under controlling state law	Mistake of law can support reasonable suspicion when objectively reasonable
Whether evidence discovered after the stop must be suppressed	Suppression necessary because initial stop unlawful	Evidence admissible because stop was lawful and subsequent detection of marijuana odor supported further action	Evidence admissible; stop lawful and marijuana odor justified search scope
Whether state caselaw supported officers’ interpretation	§ 32:53 should be read narrowly; prior state precedent doesn’t support broad reading	State appellate decision (Pena) reasonably supported a broad construction covering obscured materials	Officers’ interpretation was reasonable in light of Pena; stop upheld

United States v. Andres, 703 F.3d 828 (5th Cir. 2013) (standard of review for suppression and giving weight to inferences by local officers)
Heien v. North Carolina, 135 S. Ct. 530 (U.S. 2014) (an officer’s reasonable mistake of law can supply Fourth Amendment reasonable suspicion)
United States v. Alvarado-Zarza, 782 F.3d 246 (5th Cir. 2015) (analyzing objective reasonableness of legal mistakes under Heien)
State v. Pena, 988 So. 2d 841 (La. App. 2 Cir. 2008) (Louisiana appellate decision construing statute to find partial plate/frame obscuration unlawful)
United States v. Lopez-Moreno, 420 F.3d 420 (5th Cir. 2005) (traffic stops are seizures; review standards)
United States v. Reed, 882 F.2d 147 (5th Cir. 1989) (detection of marijuana odor justifies search of vehicle)