Sunday, January 11, 2015

US Supreme Court Heien v. North Carolina 13-604

Decision here.

   Heien was a passenger in (and owner of) a vehicle which was stopped for having a brake light out.  During the stop, Heien and the driver both consented to a search of the vehicle, and the cops found cocaine.  Heien was arrested for drug trafficking.

   Heien moved to suppress the cocaine, arguing that the stop was unlawful because the North Carolina traffic code only requires one brake light.  And although the way the traffic code is written is confusing (it requires "a stop light," but mentions that this light can be incorporated into the tail lights, and also requires that all tail lights be in working order), it turns out that Heien is right.  And so this case worked its way up through appeals, all the way to the Supreme Court.

   The Supreme Court upheld the stop.  Here's why: the Fourth Amendment requires that searches and seizures be reasonable, and therefore that officers act reasonably, but it does not require us to be perfect.  A stop can be based on a reasonable mistake of fact and still be valid.  The court uses the examples of arresting the wrong person with a warrant (who matches the suspect description) or pulling someone over for driving alone in a carpool lane only to find that there are kids in the back seat of the car.  In either case, the seizure would be valid even though it was erroneous and based on a mistake of fact.

   The court held that reasonable mistakes of law are no different than reasonable mistakes of fact.  That's not to excuse sloppy study of the law, but just recognizing that the police have to be ready to quickly apply the law to novel situations, and sometimes they don't have time to go do thorough research before deciding whether or not to detain someone.

No comments:

Post a Comment