Heien v. North Carolina

United States Supreme Court

574 U.S. 54 (2014)

Under the Fourth Amendment, a mistake of law may give rise to the reasonable suspicion required to uphold a warrantless seizure.

Relevant Facts

North Carolina (the plaintiff) prosecuted Nicholas Heien (the defendant) on cocaine-related drug charges based on what a police officer found in the defendant’s car. The officer stopped the car because only one of its two brake lights were working, believing that this violated state traffic laws.

At trial, the defendant failed to exclude the seized cocaine from evidence and was convicted. The defendant appealed to the North Carolina Court of Appeals. The appellate court reversed the trial judge's ruling, noting that the applicable North Carolina traffic law required only one working brake light, and therefore the police officer's initial traffic stop was unjustified, rendering the subsequent search and seizure as violative of the defendant’s Fourth Amendment rights. The state appealed to the North Carolina Supreme Court, which reversed the appellate court, reasoning that the officer reasonably misinterpreted an ambiguously worded traffic law, and therefore a traffic stop based on that misinterpretation was justifiable. On remand, the appellate court affirmed the trial judge's evidentiary ruling. On appeal, the North Carolina Supreme Court affirmed the appellate court judgment. The defendant then appealed to the United States Supreme Court, which granted certiorari.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 20, 2020

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Procedural History

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Citations

574 U.S. 54 (2014)