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Stops and Seizures

Heien

574 U.S. 54Supreme Court of the United States2014Date unavailable

Summary

In Heien v. North Carolina, the Supreme Court held that an officer's objectively reasonable mistake about the law can still create reasonable suspicion for a traffic stop under the Fourth Amendment. The stop began with one nonworking brake light, even though state law was later read to require only one working stop lamp. The Court affirmed because the statutory language made the officer's interpretation reasonable.

Legal Issue

Can a traffic stop satisfy the Fourth Amendment's reasonable-suspicion requirement when the officer's suspicion rests on a mistaken, but objectively reasonable, understanding of the law?

Holding

Yes. The Supreme Court held that a reasonable mistake of law can support reasonable suspicion under the Fourth Amendment. Because the North Carolina vehicle-code provisions were ambiguous enough to make Sergeant Darisse's mistake objectively reasonable, the stop was lawful.

Rule of Law

Police do not have to be legally perfect during a stop, but their legal mistake must be one a reasonable officer could make under an unclear law.

Court Reasoning

Not yet summarized.

Impact for Officers

The case matters in traffic-stop litigation, suppression motions, and police training. It encourages courts to distinguish genuinely ambiguous laws from clear statutes that officers simply misread.

What Officers Can Do

Not yet summarized.

What Officers Should Avoid

Not yet summarized.

Common Misunderstanding

Not yet summarized.