Heien v north carolina 2014

Fourth Amendment: The Exclusionary Rule Heien v. North Carolina

April 29, 2019—It is early morning in North Carolina. A State known for its scenic beauty, affectionately nicknamed the Tar Heel State. A tranquil place, really. But along Interstate 77, one detail roughly stands out in this seemingly calm scenery. Maynor Vasquez is driving his friend Nicholas Heien’s car, while his comrade is peacefully sleeping in the backseat. Their right rear brake light is broken.

They will later be charged with attempted trafficking in cocaine.

1. Background (Argued: October 6, 2014; Decided: December 15, 2014) • Summary

On that day, sergeant Darisse was on the lookout. After a brief wait, he spotted Vasquez “nervously” driving along the Interstate. The man looked suspicious. He decided to follow the vehicle, and noticed that one of its rear brake light was not working. A violation of North Carolina traffic law, he thought. Pull them over. As he walked up to the car, the officer noticed another man lying in the backseat. After questioning them, Darisse realized that something was definitely going on. Two people in the same car could not possibly have two entirely different versions of where that very same car was heading. Fishy versions, at that. After asking permission from Heien to search the car, he spotted the jackpot. On that day, sergeant Darisse found “54.2 grams of cocaine in [Nicholas Brady Heien’s] car” (OYEZ).

Both Vasquez and Heien were found guilty for two counts of trafficking cocaine. Heien filed a motion to suppress the evidence, on the ground that North Carolina statute on brake light only required one working light. Sergeant Darisse had made a mistake of law. The trial court denied Heien’s request, “concluding that the vehicle’s faulty brake light gave Darisse reasonable suspicion to initiate the stop” (Heien v. North Carolina: FindLaw). Heien appealed. The North Carolina Court of Appeals reversed the trial court. After looking deeper into the case, the appellate court concluded that the relevant code provision §20-129(g) merely required a car “to be equipped with a stop lamp” (Heien v. North Carolina). Heien’s car thus fulfilled all the requirements, as one of his rear brake light was still functioning. The justification for the stop was deemed objectively unreasonable.

The North Carolina Supreme Court reversed, on the basis that an officer’s mistake of law is reasonable, and does not violate the Fourth Amendment. On November 13, 2013, a petition for a writ of certiorari was filed, which the Supreme Court granted on December 18, 2013.

December 15, 2014—The US Supreme Court rendered its decision. The judgment of the Supreme Court of North Carolina was affirmed.

• Issue

According to Business Law and the Legal Environment, “the Fourth Amendment to the Constitution prohibits the government from making illegal searches and seizures of individuals, corporations, partnerships, and other organizations”. One circumstance under which a warrant is not required is during a traffic stop, when “police have lawfully stopped a car and then observe evidence of other crimes in the car”. In addition, the Exclusionary rule of the Fourth Amendment states that “any evidence acquired illegally… may not be used at trial”. In the case of Heien v.

North Carolina, the North Carolina traffic law that comes into play is the following: “a car must be equipped with a stop lamp on the rear of the vehicle… The stop lamp may be incorporated into a unit of one or other rear lamps” §20-129(g) (2007).

So does an officer’s mistake of law provide the ground required to justify a traffic stop under the Fourth Amendment?

2. Opinions

The Supreme Court justices voted 8-1in favor of Darisse. It held that “even assuming no violation of the state law had occurred, Darisse’s mistaken understanding of the law was reasonable, and thus the stop was valid” (Heien v. North Carolina: FindLaw).

Chief Justice Roberts delivered the opinion of the court, Judge Kagan (joined by Judge Ginsburg) wrote a concurring opinion, and Judge Sotomayor dissented.

The majority opinion holds that a mistake, when it is one of law, can still provide the reasonable suspicion necessary to justify a traffic stop. It does not violate the Fourth Amendment. One key point that Justice Roberts greatly emphasizes is “reasonableness”. Is sergeant Darisse’s mistake objectively reasonable? Could another reasonable person make the same mistake? He then concludes that since the North Carolina traffic law mentions “one or other rear lamps”, it would be reasonable to mistakenly think that this statute requires all rear brake lights to be in working condition. Sergeant Darisse’s mistake of law is reasonable, “there was reasonable suspicion justifying the stop” (Heien v. North Carolina: FindLaw).

The concurring opinion further supports the majority opinion. However, Justice Kagans (joined by Justice Ginsburg), states that an officer’s subjective understanding is irrelevant, and should not come into play when deciding the case. Instead, the Court should decide whether a statute is genuinely ambiguous. If it “requires hard interpretive work, then the officer has made a reasonable mistake” (Heien v. North Carolina: FindLaw). When interpreting the state traffic law, a brake light could be seen as a rear lamp. If it is seen as such, all brake lights must be in working order. Because the law is ambiguous, sergeant Darisse has made a reasonable mistake. His traffic stop does not violate the Fourth Amendment.

The dissenting opinion claims that the majority opinion should look beyond “reasonableness” when deciding the case. According to Justice Sotomayor, the officer’s expertise and superior position should be taken into account when determining whether or not a search or seizure is justified. Justice Sotomayor further mentions the common notion that “the law is definite and knowable” (Heien v. North Carolina: FindLaw), and that overlooking this concept would further hinder the Fourth Amendment. She then states that by deeming reasonable mistakes of law acceptable, the majority opinion drastically expands officers’ authority.

3. Personal Opinion

POINT: I (respectfully) disagree with the Supreme Court’s verdict, as I think the officer’s mistake was not that “of reasonable men” (Heien v. North Carolina: FindLaw). IDENTIFY THEORIES/CONCEPTS: The Fourth Amendment “prohibits the government from making illegal searches and seizures” (Beatty and Samuelson). One exception to warrant is traffic stop: if police have lawfully stopped car, they are permitted to search without a warrant. In order to do so, they have to provide a reasonable justification for making the traffic stop. This Amendment was put in place to protect the common people from the state’s potential abuse of power. Officers are allowed a margin of error in the field of action. A “reasonable” mistake would be

one that another reasonable individual would make, under similar circumstances. CONNECT THE FACTSà ANALYSIS: Allowing officers to make unreasonable mistakes of law would dangerously expand their power. Officers should be held at a higher standard, given their position of expertise.

I most align with Justice Sotomayor’s dissenting opinion. Darisse’s mistake of law was unreasonable, as it concerns routine work and is a blatant, tangible mistake. Officers, given their superior position, should be expected to know essential information on the work they perform on a daily basis. Such information would include knowing whether or not the State statute requires all, one, or no brake light to be in working conditions. Not knowing so would be a blatant, tangible mistake, as having a broken brake light is a common occurrence that could happen to the everyday citizen. If an officer mistakenly stops and punishes one car for having a broken rear brake light (when a given law only requires one brake light to work), what would happen to the other ten cars that he/she could encounter that same day that might have the same problem? Another reasonable individual, under similar circumstances and with the same expertise level, would not have committed the same mistake. Given their superior position, officers should also not be held above the common motto: “Ignorance of law is no excuse”.

KEY TAKEAWAY: Darisse’s mistake of law was unreasonable. Therefore, he failed to provide a reasonable justification for making the traffic stop, and has violated the Fourth Amendment.

Allowing officers such a high margin of error would be similar to unchaining a powerful beast. Who knows what will happen as soon as it is free? Perhaps there was a better way to handle that one detail that roughly stood out in the middle of the seemingly calm Tar Heel State…

Works Cited Lieberman, Jethro, Don Mayer, George Siedel and Daniel Warner. The Legal Environment and Business Law. 1st Version. 2012. Print.

"Heien v. North Carolina." n.d. SCOTUSblog. Web. 3 November 2015. .

"Heien v. North Carolina: FindLaw." n.d. FindLaw. Web. 3 November 2015.