Heien v North Carolina

A stop initiated by an Officer's reasonable mistake of law is not a violation of the Fourth Amendment of the United States Constitution.

Petitioner was a passenger when stopped by a sheriff’s deputy because only one brake light came on when the driver slowed down. The deputy issued a warning ticket to the driver for the brake light, he returned to the vehicle to question Petitioner and the driver because they appeared nervous. After the driver consented to a search of the vehicle, and Petitioner consented to a search of his belongings, the search revealed cocaine belonging to Petitioner. Petitioner was charged with attempted trafficking of cocaine. The trial court denied Petitioner’s motion to suppress evidence, and Petitioner pled guilty, but preserved his right to appeal the suppression decision. The North Carolina Court of Appeals reversed the trial court decision and held that the initial stop was not valid because driving with only one working brake light is not a violation of the relevant provision of the North Carolina Vehicle Code. The State appealed and the North Carolina Supreme Court reversed, holding that the deputy’s search initiated by a reasonable mistake of law does not violate the Fourth Amendment, and affirmed the trial court’s decision. The United States Supreme Court granted certiorari on the issue of mistake of law. The Court held that the Fourth Amendment allows for some mistakes as long as the government official was acting reasonably and since the North Carolina Court of Appeals had never previously interpreted the brake light statute, the deputy was subjectively reasonable in his interpretation of the law, and thus the stop was valid.