In Heien v. North Carolina, the U.S. Supreme Court held that a police officer’s mistake of the law does not support a motorist’s claim of illegal search and search. A North Carolina police officer stopped Heien’s car because only one of Heien’s brake lights was working. The police searched Heien’s car and found cocaine. Heien moved the trial court to suppress the cocaine because the police officer’s reason for stopping the car was illegal. In North Carolina, it is not illegal to drive with only one functioning brake light. The trial court rejected Heien’s argument, but the North Carolina Court of Appeals agreed with Heien and reversed the trial court’s decision. The case was appealed to the North Carolina Supreme Court which agreed with the trial court and reversed the Court of Appeals decision. The North Carolina Supreme Court held no violation of state law occurred because the police officer’s mistaken understanding of the law was reasonable. The U.S. Supreme Court affirmed the North Carolina Supreme Court decision.
The Fourth Amendment requires government officials to act reasonably, not perfectly, and the Fourth Amendment give those officials “fair leeway for enforcing the law.” Bringar v. U.S., 338 U.S. 160, searches and seizure based on mistakes of fact may be reasonable. Illinois v. Rodriguez, 497 U.S. 177, the limiting factor is that “mistakes must be those of reasonable men.” The Fourth Amendment tolerates only objectively reasonable mistakes of law. Heien was an 8 to 1 decision with Justice Sotomayor dissenting. In the Heien case, the officer stopped a vehicle because one of its 2 brake lights was out. It was determined that in North Carolina only a single brake light is required under North Carolina law. In order to stop a vehicle, a police officer must have reasonable suspicion that the motorist violated the law. Reasonable suspicion is “a particularized and objective basis for suspecting the particular person stopped if breaking the law. The U.S. Supreme Court has previously determined that seizures and searches based on reasonable mistakes of fact can be legal. Hill v. California, 401 U.S. 797, the Heien decision further erodes Fourth Amendment protections of civil liberties. The Heien case is in line with Whren v. U.S., where the U.S. Supreme Court held that an officer’s subjective motivations do not render a traffic stop illegal, but at least in Whren, the officer’s pretext was a violation of an actual law. According to the Heien decision, trial courts no longer need to interpret statutory language. Trial courts can simply decide whether the police officer’s misinterpretation of the law was reasonable.