Thought I would post a brief summary of an interesting Supreme Court case, which I had to write up for my Criminal Law class.
Heien v. North Carolina US 574 U.S. (2014)
On April 29th, 2009, Nicholas Heien was arrested after being found in possession of cocaine during a traffic stop. The traffic stop had been initiated by Sergeant Darisse of the Surry County Sheriffs department, North Carolina, due to a non-functional brake light. Sergeant Darisse pulled over the defendant who was a passenger in his own vehicle, being driven by Maynor Javier Vasquez. During the conversation with the defendants, Sergeant Darisse noted that that Mr. Heien was acting nervous, the deputy upon asking the driver for permission to search the vehicle but was directed to ask Mr. Heien (the owner). The defendant said that he, quote “didn’t really care” and the officer searched the vehicle, finding a quantity of cocaine.
Mr. Heien and Mr. Vasquez were then arrested and charged with cocaine trafficking. Mr. Heien file a motion to suppress the results of the search, due to the wording of North Carolina law, which does not require multiple working brake lights. Therefore claiming that the brake light failure was not reasonable grounds for search and seizure. Sergeant Darisse was not aware that the law did not require all equipped brake lights to be functional on a motor vehicle. The court denied the motion and Mr Heien pled guilty but reserved his right to appeal the motion to suppress. The trial courts decision was reversed by the North Carolina Court of Appeals, but then upheld by the North Carolina Supreme Court when appealed by the State of North Carolina. Mr. Heien then filed a writ of certiorari, for the U.S. Supreme Court to hear the case.
Is evidence of a crime, gained by a law enforcement officers misunderstanding of the written law, protected under 4th amendment of the constitution, which, guarantees freedom from unreasonable search and seizure.
No, evidence of a crime is not protected under the 4th amendment, with the condition that the law enforcement officer has made a reasonable misinterpretation of the written law.
The Supreme Court upheld the trail courts denial of suppression, overturning the the decision of the North Carolina Supreme Court. Law enforcement can seize evidence of a crime during a traffic stop even if the traffic stop was initiated due to a reasonable misunderstanding of the written law, but not due to ignorance of the law.
The Court found in a an 8-1 majority that due to the unclear wording of the North Carolina automotive brake light and taillight code, and that the law enforcement officer was duly knowledgable of the law, the evidence would still be permissible even had Mr. Heien not given permission to search the vehicle. This is because an objectively reasonable misinterpretation not incompatible with reasonable, individual suspicion, required by the 4th Amendment. This ruling does not permit violation of the 4th amendment due ignorance of the law, or sloppy police work. The one dissenting vote maintained that the interpretation of the 4th amendment should revolve solely around the facts of the law not interpretation, however the Court deemed that the burden of proof to assert reasonable misunderstanding is so high that it did not represent a threat to erode the 4th amendments protections.