A police officer stopped the car in which Heien was a passenger because it only had one operating brake light. During the stop, the officer received consent to search the car and discovered cocaine inside a duffel bag. Heien and the driver were charged with trafficking cocaine.
Heien argued North Carolina law did not require a vehicle to be equipped with more than one working brake light. As a result, Heien claimed the traffic stop constituted an unlawful seizure in violation of the Fourth Amendment; therefore, the cocaine should have been suppressed.
Whether a police officer’s mistake of law can provide reasonable suspicion to support a traffic stop.
Yes, as long as the mistake is objectively reasonable.
The Supreme Court held that the Fourth Amendment requires government officials to act reasonably, not perfectly, and gives those officials “fair leeway for enforcing the law.” In this case, the Supreme Court found there was little difficulty in concluding the officer’s mistake of law was reasonable. The North Carolina vehicle code that requires “a stop lamp” also provides that the lamp “may be incorporated into a unit with one or more other rear lamps,” and that “all originally equipped rear lamps” must be “in good working order.” Although the North Carolina Court of Appeals held that “rear lamps” do not include brake lights, the word “other,” coupled with the lack of state-court precedent interpreting the provision, made it objectively reasonable for the officer to believe that a faulty brake light constituted a violation.
574 U.S. ___, 135 S. Ct. 530 (2014)