Supreme Court of the United States · 2014 · Criminal Procedure
25 Fla. L. Weekly Fed. S 20 (2014)
Updated
Criminal ProcedureFourth AmendmentReasonable SuspicionTraffic Stopsmistake of lawtraffic stopobjectively reasonablebrake light
Facts
Sergeant Matt Darisse followed a Ford Escort and stopped it after seeing that only the left brake light illuminated when the car braked. Darisse believed the faulty right brake light violated North Carolina law. During the stop, the occupants acted nervously and gave inconsistent answers, and Heien, the car's owner, consented to a search. Officers found cocaine in the car, and Heien moved to suppress on Fourth Amendment grounds.
Issue
Can an officer's reasonable mistake about the meaning of a traffic law supply the reasonable suspicion required for a stop under the Fourth Amendment? More specifically, was the stop valid even if North Carolina law required only one working brake light?
Rule
The Fourth Amendment requires reasonableness, not perfection. Reasonable suspicion may rest on an objectively reasonable mistake of law, just as it may rest on an objectively reasonable mistake of fact, so long as the officer's legal error concerns an unclear law and is itself objectively reasonable.
🔒
See the holding & full analysis
Create a free KwikCourt account to unlock the rest of this brief — and practice the case.
The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Columbus, Ohio, Officer Lena Ortiz stopped Devin Marsh after seeing that one of his two rear side-marker lamps was dark. Ortiz relied on a state vehicle code provision requiring "a rear marker lamp," but another subsection stated that the lamp could be combined with "one or more other rear lamps," and no Ohio appellate court had interpreted whether all originally equipped lamps had to function. A later court held the code required only one working marker lamp.
Was the stop consistent with the Fourth Amendment?
Explanation. The Fourth Amendment requires reasonableness, not perfection. A stop may be supported by reasonable suspicion resting on an objectively reasonable mistake of law, just as on an objectively reasonable mistake of fact. Here, the statute was unclear, its text pointed in competing directions, and there was no prior appellate construction, so the officer's misunderstanding could be objectively reasonable. The officer's subjective good faith or training is not the test.