Heien v. North Carolina

135 S. Ct. 530 (2014)

Facts

Darisse thought the driver of a car looked “very stiff and nervous,” so he pulled onto the interstate and began following the Escort. The car braked as it approached a slower vehicle, but only the left brake light came on. Noting the faulty right brake light, Darisse activated his vehicle’s lights and pulled the car over. Vasquez sat behind the wheel, and D lay across the rear seat. Darisse gave Vasquez the warning ticket. Darisse had become suspicious, and the two gave inconsistent answers about their destination. Darisse asked whether the men were transporting various types of contraband. Darisse asked whether he could search the car. Vasquez said he had no objection, but told Darisse he should ask D because D owned the car. D gave his consent. In the side compartment of a duffle bag, Darisse found a sandwich bag containing cocaine. Both men were arrested. The State charged D with attempted trafficking in cocaine. The trial court denied the suppression motion, concluding that the faulty brake light had given Darisse reasonable suspicion to initiate the stop. D pleaded guilty but reserved his right to appeal the suppression decision. The North Carolina Court of Appeals reversed because driving with only one working brake light was not actually a violation of North Carolina law. The State appealed, and the North Carolina Supreme Court reversed. Because Darisse’s mistaken understanding of the vehicle code was reasonable, the stop was valid. “An officer may make a mistake, including a mistake of law, yet still act reasonably under the circumstances.