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Police Justified in Making Stops Regardless of Mistake of Law

Date Posted to Site: 12/16/2014

WASHINGTON — The Supreme Court ruled Monday that police can use evidence seized during a traffic stop even if it turns out the officers were mistaken in thinking the driver had broken the law when they pulled the vehicle over.

The 8-1 decision written by Chief Justice John Roberts said that such a stop does not violate the Constitution's protection against unreasonable searches.

The ruling came in a North Carolina case in which a police officer pulled over Nicholas Heien's car because the right brake light was out, although the left one still worked. A search led to the discovery of cocaine in the trunk.

A state appeals court said the stop was impermissible because state law only requires a car to have one functioning brake light. But the state's highest court reversed, saying that the officer's misunderstanding of law was reasonable.

The Supreme Court agreed, finding that the Fourth Amendment requires police to act reasonably, but not perfectly. Roberts said that just as a police officer's mistake of fact can justify a traffic stop, a reasonable misunderstanding about the law can also satisfy the Constitution.

Heien had argued that ignorance of the law is no excuse for citizens accused of crimes and said there shouldn't be a double standard for police. But Roberts said that simply means the state can't impose a punishment for something that isn't illegal.

"Heien is not appealing a brake-light ticket," Roberts said. "He is appealing a cocaine-trafficking conviction as to which there is no asserted mistake of fact or law."

The state had argued that refusing to allow such stops would inject too much uncertainty into the daily actions of police in the field who need to make quick decisions. Reasonable mistakes of law are acceptable, the state argued, especially when dealing with a "confusing" law that might be subject to different interpretations.

In this case, North Carolina's antiquated law required cars made after 1955 to have a "stop lamp." No court had ever interpreted the decades-old law in the modern era to require only one working brake light.

Justice Sonia Sotomayor was the lone dissenter. She said an officer's mistake of law "no matter how reasonable, cannot support the individualized suspicion necessary to justify a seizure under the Fourth Amendment."




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