15 December 2014

Law in Plain English: Heien v. North Carolina

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogHeien v. North Carolina

Argument: Oct 6 2014 (Aud.)

Background: The defendant Nicholas Heien was the passenger in a vehicle that was stopped for a non-functioning rear taillight. The subsequent consent search revealed cocaine. Heien sought to suppress the evidence obtained during the search, alleging that the stop was an illegal seizure in violation of the Fourth Amendment. The trial court denied the defendant's motion to suppress, but the North Carolina Court of Appeals reversed, finding that that North Carolina's statutes only required one working brake light. Because one taillight was working, Heien's vehicle was not in violation of the law. As a result, the stop was objectively unreasonable and therefore unconstitutional. The Supreme Court of North Carolina reversed, finding that the police officer's mistake of law was objectively reasonable and that he had reasonable suspicion to stop the vehicle in which the defendant was a passenger.

Issue: The question before the Court is whether a police officer’s mistake of law can provide the individualized suspicion that the Fourth Amendment requires to justify a traffic stop.

Holding: In an 8-1 decision, the Supreme Court ruled that because the police officer's mistake of law was reasonable, there was reasonable suspicion justifying the stop under the Fourth Amendment. The Fourth Amendment requires government officials to act reasonably, not perfectly, and gives those officials “fair leeway for enforcing the law.”
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