Heien v. North Carolina
Citation and Court
574 U.S. 54 (2014) — Supreme Court of the United States
Facts
An officer stopped Heien’s car because one of its two brake lights was out. During the stop, the officer obtained consent to search the vehicle and found cocaine. Heien argued that North Carolina law only required one working brake light, so the stop—based on a legal mistake—was invalid. The officer’s reading of the statute was objectively reasonable, even though incorrect.
Issue
Does the Fourth Amendment permit a traffic stop based on an officer’s objectively reasonable, but mistaken, understanding of the law?
Holding
Yes; a stop based on an objectively reasonable mistake of law does not violate the Fourth Amendment.
Rule / Doctrine
Reasonable suspicion can rest on a mistaken understanding of the law if the mistake is objectively reasonable. The Fourth Amendment requires only reasonable suspicion, not infallible knowledge; an officer who makes an objectively reasonable legal mistake has not acted unreasonably.
Significance
Heien extends the principle from Illinois v. Rodriguez (reasonable mistake of fact) to mistakes of law, holding that objectively reasonable legal errors can still provide the requisite suspicion for a stop. It is a significant limit on the exclusionary rule where police reasonably, if incorrectly, believe conduct violates the law.