WASHINGTON (CN) – Though a traffic-stop drug bust stemmed from a cop’s misunderstanding of brake-light rules, the search was proper, the Supreme Court ruled Monday.
Sgt. Matt Darisse with the Sheriff’s Department in Surry County, N.C., effected the stop in question on April 29, 2009, after noticing a car with a broken brake light.
The driver stepped outside as instructed and answered the officer’s questions, saying he and his passenger were going to West Virginia. Nicholas Heien, the passenger, was lying in the back seat beneath a blanket.
Darisse was prepared to issue the driver a warning citation for the brake light, but the allegedly suspicious behavior of the driver and Heien led officers to check the men’s records.
Darisse issued the citation, asked the driver more questions, and then asked for permission to search the vehicle.
The search, to which Heien consented, produced a duffle bag, which contained a grocery bag, which contained a sandwich bag of drugs covered in paper towels.
After the Surry County Superior Court denied Heien’s motion to suppress, Heien pleaded guilty in 2010 to attempted trafficking in cocaine by transportation and possession.
The North Carolina Supreme Court found no Fourth Amendment issues, and the U.S. Supreme Court took up the case earlier this year.
It affirmed 8-1 Monday, looking only at whether the issue of the brake light helped Heien.
“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,” Chief Justice John Roberts wrote for the majority. “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.”
The 13-page opinion notes that “reasonable men make mistakes of law, too, and such mistakes are no less compatible with the concept of reasonable suspicion.”
Since prosecutors often quote the maxim “ignorance of the law is no excuse” to their advantage, Heien called it “fundamentally unfair to let police officers get away with mistakes of law when the citizenry is accorded no such leeway,” Roberts noted.
“Though this argument has a certain rhetorical appeal, it misconceives the implication of the maxim,” he continued. “The true symmetry is this: Just as an individual generally cannot escape criminal liability based on a mistaken understanding of the law, so too the government cannot impose criminal liability based on a mistaken understanding of the law. If the law required two working brake lights, Heien could not escape a ticket by claiming he reasonably thought he needed only one; if the law required only one, Sergeant Darisse could not issue a valid ticket by claiming he reasonably thought drivers needed two. But just because mistakes of law cannot justify either the imposition or the avoidance of criminal liability, it does not follow that they cannot justify an investigatory stop. And Heien is not appealing a brake-light ticket; he is appealing a cocaine-trafficking conviction as to which there is no asserted mistake of fact or law.”
Justice Sonia Sotomayor wrote in dissent that “determining whether a search or seizure is reasonable requires evaluating an officer’s understanding of the facts against the actual state of the law.”
“To my mind, the more administrable approach – and the one more consistent with our precedents and principles – would be to hold that an officer’s mistake of law, no matter how reasonable, cannot support the individualized suspicion necessary to justify a seizure under the Fourth Amendment,” Sotomayor wrote.
For Justice Elena Kagan, deciding whether an officer’s mistake of law can support a seizure requires courts to answer a “straightforward question of statutory construction.”
“If the statute is genuinely ambiguous, such that overturning the officer’s judgment requires hard interpretive work, then the officer has made a reasonable mistake,” Kagan’s concurring opinion, joined by Justice Ruth Bader Ginsburg, states. “But if not, not. As the solicitor general made the point at oral argument, the statute must pose a ‘really difficult’ or ‘very hard question of statutory interpretation.'”
Kagan emphasized that “an officer’s ‘subjective understanding’ is irrelevant.”
“That means the government cannot defend an officer’s mistaken legal interpretation on the ground that the officer was unaware of or untrained in the law,” Kagan continued. “And it means that, contrary to the dissenting opinion in the court below, an officer’s reliance on ‘an incorrect memo or training program from the police department’ makes no difference to the analysis. Those considerations pertain to the officer’s subjective understanding of the law and thus cannot help to justify a seizure.”
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