Do law enforcement officials violate the Fourth Amendment rights of motorists when they initiate a traffic stop based on a misunderstanding of vehicle traffic laws and uncover evidence of criminal activity during a subsequent search of the car they mistakenly pulled over?
That was precisely the issue before the Supreme Court of the United States in Heien v. North Carolina, a case decided this past Monday.
According to the facts, a North Carolina police officer pulled over the vehicle carrying the petitioner and a friend for having a broken brake light sometime back in 2009.
While the officer believed that the broken brake light constituted a traffic violation under state law, the law only requires one functioning “stop lamp,” something that the petitioner’s car did have.
After initiating the traffic stop, the officer performed a search of its interior with the consent of the petitioner and discovered a sandwich bag full of cocaine.
The petitioner, who was ultimately charged with attempted drug trafficking, sought to have the cocaine excluded as evidence on the grounds that his Fourth Amendment rights had been violated by the mistaken traffic stop.
While the North Carolina Court of Appeals agreed with this argument, basing its decision largely on the misinterpretation of the state’s vehicle traffic laws, the North Carolina Supreme Court ultimately reversed the decision, finding that the matter instead hinged on whether the mistake made by the officer was reasonable and that all indications were that it had been.
In an 8-1 decision, SCOTUS affirmed this decision, finding that the inquiry as to whether the petitioner’s Fourth Amendment rights had been violated did indeed hinge on whether the mistake was reasonable, as the language of the amendment expressly prohibits “unreasonable searches and seizures.”
Here, the justices found that the officer’s mistaken understanding of his state’s vehicle traffic laws was objectively reasonable under the circumstances and that the evidence secured during the search is indeed admissible.
It is worth noting that the opinion, written by Chief Justice John Roberts, indicated that the decision should perhaps not come as a surprise given that SCOTUS has long permitted searches and seizures based on a police officer’s reasonable misunderstanding of the facts.
Furthermore, it noted that the decision wouldn’t have the effect of discouraging police officers from taking the time to learn the laws of their respective states, as only objectively reasonable mistakes of the law were permissible.
“An officer can gain no Fourth Amendment advantage through a sloppy study of the laws he is duty-bound to enforce,” reads the opinion.
What are your thoughts on this decision?
If you are facing criminal charges, consider speaking with an experienced legal professional as soon as possible. Together, you can examine the circumstances surrounding your arrest to uncover any possible violations of your constitutional rights and examine all of your options moving forward.
Source: The New York Times, “Court rules for mistaken police officer,” Adam Liptak, Dec. 15, 2014
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