Heien v. North Carolina Case Brief

Facts of the case

On April 29, 2010, Sergeant Darisse of the Surry County Sheriff’s Department observed Maynor Javier Vasquez driving north on I-77 with a broken brake light. When Darisse pulled over the vehicle, he noticed another man, Nicholas Heien, lying under a blanket in the backseat. Darisse spoke with the two men, felt that their stories did not match up, and was concerned that Heien had not gotten up from the back seat. Darisse asked for permission to search the vehicle. Heien agreed, and Darisse found a bag containing 54.2 grams of cocaine in the car.A grand jury indicted Heien for two counts of trafficking cocaine. Heien filed a motion to suppress the evidence discovered during the search of his vehicle, and the trial court denied the motion. The North Carolina Court of Appeals reversed the trial court and held that the traffic stop was not objectively reasonable because North Carolina law only required one working brake light. The North Carolina Supreme Court reversed and held that when an officer’s mistake of the law is reasonable, it may give rise to the reasonable suspicionrequired for a traffic stop of a vehicle under the Fourth Amendment. That North Carolina Supreme Court sent the case back to the state Court of Appeals.The North Carolina Court of Appeals found no error in the trial court’s judgment. A dissenting judge, however, stated that the North Carolina Supreme Court’s ruling created fundamental unfairnessbecause it held citizens to the traditional rule that ignorance of the law is no excusewhile allowing police to be ignorant of the law. Based on this dissent, Heien again appealed to the North Carolina Supreme Court which rejected Heien’s appeal.

CONCLUSION

The Supreme Court of the United States affirmed the state supreme court’s decision. The Court held that under the Fourth Amendment , reasonable suspicion could rest on a mistaken understanding of the scope of a legal prohibition. The Fourth Amendment tolerated only reasonable mistakes, and those mistakes, whether of fact or of law, had to be objectively reasonable. An officer’s error of law in stopping a vehicle for a violation of N.C. Gen. Stat. § 20-129(g) because one of its two brake lights was out was objectively reasonable, thereby justifying the stop, where the statute had not previously been construed by North Carolina’s appellate courts, and under the language of the statute, it was reasonable to conclude that the use of the word othermeant that the rear lamps discussed in N.C. Gen. Stat. § 20-129(d) included brake lights.

  • Advocates: Jeffrey L. Fisher for the petitioner Robert C. Montgomery for the respondent Rachel P. Kovner on behalf of the united states as amicus curiae, supporting respondent
  • Petitioner: Nicholas B. Heien
  • Respondent: State of North Carolina
  • DECIDED BY:Roberts Court
  • Location: Interstate 77
Citation: 574 US 54 (2014)
Granted: Apr 21, 2014
Argued: Oct 6, 2014
Decided: Dec 15, 2014
Heien v. North Carolina Case Brief