Heien v. North Carolina (574 U.S. 54)

U.S. Supreme Court · decided December 15, 2014 · Supreme Court Database (Spaeth)

Citation
574 U.S. 54 · 135 S. Ct. 530
Decided
December 15, 2014
Term
October Term 2014
Vote
8–1
Majority author
Justice Roberts
Issue area
Criminal Procedure
Disposition
Affirmed
Outcome
Petitioning party lost
Ideological direction
Conservative

Opinion excerpt

Chief Justice ROBERTSdelivered the opinion of the Court. The Fourth Amendment prohibits "unreasonable searches and seizures." Under this standard, a search or seizure may be permissible even though the justification for the action includes a reasonable factual mistake. An officer might, for example, stop a motorist for traveling alone in a high-occupancy vehicle lane, only to discover upon approaching the car that two children are slumped over asleep in the back seat. The driver has not violated the law, but neither has the officer violated the Fourth Amendment. But what if the police officer's reasonable mistake is not one of fact but of law? In this case, an officer stopped a vehicle because one of its two brake lights was out, but a court later determined that a single working brake light was all the law required. The question presented is whether such a mistake of law can nonetheless give rise to the reasonable suspicion necessary to uphold the seizure under the Fourth Amendment. We hold that it can. Because the officer's mistake about the brake-light law was reasonable, the stop in this case was lawful under the Fourth Amendment. I On the morning of April 29, 2009, Sergeant Matt Darisse of the Surry County Sheriff's Department sat in his patrol car near Dobson, North Carolina, observing northbound traffic on Interstate 77. Shortly before 8 a.m., a Ford Escort passed by.…

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