State v. Heien
2012 N.C. LEXIS 1003, 366 N.C. 271, 737 S.E.2d 351 (2012)
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Rule of Law:
A law enforcement officer's objectively reasonable mistake of law can give rise to the reasonable suspicion required to justify a traffic stop under the Fourth Amendment.
Facts:
- Sergeant Matt Darisse, a Surry County Sheriff's deputy, was observing traffic on Interstate 77.
- He observed a Ford Escort, with Maynor Javier Vasquez driving and Nicholas Brady Heien as a passenger, apply its brakes.
- When the brakes were applied, Sergeant Darisse saw the right rear brake light fail to illuminate, while the left brake light functioned properly.
- As the Escort was pulling to a stop, the right brake light flickered on.
- During the stop, Vasquez and Heien provided conflicting information about their travel destination.
- Heien, the vehicle's owner, consented to a search of the Escort.
- The subsequent search uncovered a bag containing cocaine in the rear of the vehicle.
Procedural Posture:
- Nicholas Brady Heien was charged in Surry County Superior Court with attempting to traffic in cocaine.
- Heien filed a pre-trial motion to suppress the evidence, arguing the initial traffic stop was an unconstitutional seizure.
- The trial court denied the motion to suppress, concluding the officer had a reasonable and articulable suspicion for the stop.
- Following his conviction, Heien (as appellant) appealed to the North Carolina Court of Appeals.
- The Court of Appeals reversed the trial court, holding that the relevant statute required only one working brake light and that a stop based on an officer's mistake of law was objectively unreasonable.
- The State of North Carolina (as appellant) petitioned the Supreme Court of North Carolina for discretionary review, which was granted.
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Issue:
Does a police officer's reasonable but mistaken belief that a driver has violated a traffic law provide the necessary reasonable suspicion to justify a traffic stop under the Fourth Amendment?
Opinions:
Majority - Justice Newby
Yes. A police officer's reasonable mistake of law can provide the necessary reasonable suspicion for a traffic stop. The Fourth Amendment demands reasonableness, not perfection, from law enforcement officers. The reasonable suspicion standard is a 'commonsense, nontechnical' concept based on the totality of the circumstances, and an officer's action is not rendered unconstitutional simply because it is based on a reasonable, but ultimately incorrect, interpretation of an ambiguous statute. To hold otherwise would require officers to be 'omniscient' legal technicians rather than reasonable and prudent individuals. The court finds no constitutional requirement to distinguish between an officer's reasonable mistake of fact and a reasonable mistake of law, as both should be analyzed under the same objective reasonableness standard. In this case, the North Carolina statutes regarding brake lights were ambiguous, and Sergeant Darisse's belief that a non-functioning brake light constituted a violation was objectively reasonable.
Dissenting - Justice Hudson
No. A police officer's mistake of law cannot form the basis for reasonable suspicion. The constitutionality of a stop depends on whether the objective facts show an actual violation of the law, not on the officer's subjective belief about what the law is. The majority's holding introduces subjectivity into the Fourth Amendment analysis, effectively creates a 'good faith exception' that North Carolina has previously rejected, and aligns with a minority of federal circuits. This decision improperly grants law enforcement an interpretive role that belongs to the legislature and judiciary, and it creates a fundamental unfairness by holding citizens to the standard that 'ignorance of the law is no excuse' while excusing law enforcement officers for the same.
Analysis:
This decision establishes a significant precedent in North Carolina by holding that a reasonable mistake of law can justify a Fourth Amendment seizure. It rejects the bright-line rule, followed by a majority of federal circuits at the time, that a mistake of law is per se unreasonable. By equating reasonable mistakes of law with reasonable mistakes of fact, the court expanded the scope of permissible police conduct, allowing seizures to be upheld even when no actual legal violation has occurred. This ruling lowers the bar for what constitutes reasonable suspicion and has a broad impact on suppression motions in cases initiated by traffic stops based on complex or ambiguous statutes.
