Heien v. North Carolina, 13-604 (December 15, 2015)
This is a police mistake of law case. Sgt. Darisse noticed a vehicle with one of its brake lights not working and pulled over the driver. After receiving consent to search the vehicle he discovered cocaine and arrested the passenger, Heien. The trial court denied Heien’s motion to suppress where he argued the North Carolina traffic code requires only one light to be operational. The court of appeals reversed the denial holding that since Darisse was mistaken on the law, the stop was objectively unreasonable. The State Supreme Court reversed in turn holding the technical mistake of law did not invalidate the reasonableness of the stop. Heien appealed and the U.S. Supreme Court granted review.
The Court first held the Fourth Amendment requires government officials to act reasonably, not perfectly, and gives those officials “fair leeway for enforcing the law.” The limiting factor is that “the mistakes must be those of reasonable men.” Mistakes of law are no less compatible with the concept of reasonable suspicion, which arises from an understanding of both the facts and the relevant law. Whether an officer is reasonably mistaken about the one or the other, the result is the same. The North Carolina traffic codes also require integration of brake lights into the car system and it was reasonable for Sgt. Darisse to believe the law required both to be operational.
If you would like to read this opinion click here. ROBERTS, C. J., delivered the opinion of the Court, in which SCALIA, KENNEDY, THOMAS, GINSBURG, BREYER, ALITO, and KAGAN, JJ., joined. KAGAN, J., filed a concurring opinion, in which GINSBURG, J., joined. SOTOMAYOR, J., filed a dissenting opinion. The docket page with attorney information can be found here.