Mistakes, Reasonable Mistakes, and Unforgiveable Mistakes: The U.S. Supreme Court’s Ruling in Heien v. North Carolina

On December 15, 2014, the U.S. Supreme Court decided Heien v. North Carolina, holding that a law enforcement officer’s reasonable mistake of law does not invalidate the search of a vehicle and the seizure of contraband found therein. “The question here is whether reasonable suspicion can rest on a mistaken understanding of the scope of a legal prohibition. We hold that it can.”

The case began when a sheriff’s department sergeant observed a car traveling northbound on Interstate 77 in rural North Carolina. The officer thought the driver looked “very stiff and nervous,” and he began following the car. After several miles, the vehicle braked as it approached a slower vehicle, but only one brake light illuminated. The officer pulled the car over under the belief that North Carolina law required that at least two brake lights should be operable.