U.S. Supreme Ct. - Dec. 15, 2014

by: Frangieringer and Abassos • December 15, 2014 • no comments

Mistake of Law – A Reasonable, But Wrong, Interpretation of an Ambiguous Statue Does Not Void a Stop under the Fourth Amendment

Reasonable suspicion to stop a person based on an objectively reasonable mistake of law does not void the stop. Here, defendant was stopped for having only one functioning tail light. The officer believed that North Carolina required two working tail lights, where, in fact, it only required one. In the subsequent stop and search of the car, a sandwich bag of cocaine was found. Because the North Carolina courts had not interpreted the “stop lamp” provision, and the statute could have reasonably been interpreted as requiring two working tail lights, the officer’s interpretation of the law was reasonable.

Kagan’s concurrence: An objectively reasonable mistake of law is not based on unawareness of the law or being untrained in the law. Furthermore, the statute that was incorrectly interpreted by the officer must present a “really difficult” or “very hard question of statutory interpretation.” Because the statute at issue here could reasonably have been interpreted the same way as the officer interpreted it, the stop did not violate the Fourth Amendment.

Sotomayor’s dissent: Nothing in the Court’s precedent extends the basis for the mistake of fact doctrine to mistake of law. Such a ruling will encourage courts to interpret the reasonability of an officer’s actions instead of interpreting the construction of a statute. Furthermore, the Court has failed to articulate clear principles for what constitutes a reasonable mistake of law.

Heien v. North Carolina, ___ US ___ (2014).