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Wednesday, December 17, 2014

Supreme Court Upholds Traffic Stop Based on Reasonable Mistake of Law

The U.S. Supreme Court decided a case regarding probable cause for traffic stops. In Heien v. North Carolina, the court concluded that an officer's reasonable mistake of law can still support probable cause to make a traffic stop.  

In the case, a police officer had stopped a vehicle with a broken brake light based on the officer's belief that a North Carolina law that required vehicles to maintain rear lights in factory-installed condition meant that both rear brake lights had to be in working order. While issuing a warning ticket for the broken light, the officer became suspicious and requested consent to search the vehicle, which was granted.  The officer found cocaine in the car and arrested the driver for attempted drug trafficking. 

The driver filed a motion to suppress the evidence, arguing that the officer had no probable cause to make the initial traffic stop because North Carolina law did not require both lights to be in working order.  The trial court agreed that the law only required one brake light to be in working order, but allowed the evidence in based on the officer's reasonable, although mistaken, belief in the law.  The appeals court reversed, finding that the officer's mistake could not justify probable cause, but the state supreme court reversed again.  The case was ultimately appealed to the U.S. Supreme Court.  

On appeal, the Supreme Court concluded that the officer's mistake in believing the car violated the law was 'reasonable' and satisfied the requirements of probable cause for the traffic stop.  The Supreme Court noted that the Fourth Amendment requires government officials to act reasonably, not perfectly, and gives those officials “fair leeway for enforcing the law.” As a result, the officer had probable cause to stop the vehicle based on a reasonable "mistake in law."  Therefore, the evidence was properly admitted.

Post Authored by Julie Tappendorf


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