Heien v. North Carolina (2014)
- Docket
- 13-604
- Decided
- 2014-01-01
Summary
Question: Does a police officer's mistake of law provide the individualized reasonable suspicion that the Fourth Amendment requires to justify a traffic stop? Conclusion: Yes. Chief Justice John G. Roberts, Jr., delivered the opinion for the 8-1 majority. The Court held that a search or seizure is reasonable under the Fourth Amendment when an officer has made a reasonable factual or legal mistake. Because Fourth Amendment jurisprudence turns on the question of reasonableness, governing officials have traditionally been allowed leeway to enforce the law for the community's protection. As long as the mistake of fact or law in question was reasonable, the Fourth Amendment does not hold such mistakes to be incompatible with the concept of reasonable suspicion. However, the Court also held that those mistakes must be objectively reasonable; an officer cannot gain the benefits of Fourth Amendment reasonableness through a sloppy or incomplete knowledge of the law. In her concurring opinion, Justice Elena Kagan emphasized that the majority opinion's analysis was limited to when the mistake of law in question is an objectively reasonable one. Justice Kagan also wrote that the test to determine whether an officer made an objectively reasonable mistake is much more stringent than the one to determine whether a government official is entitled to qualified immunity. Justice Ruth Bader Ginsburg joined in the concurring opinion. Justice Sonia Sotomayor wrote a dissenting opinion in which she argued that Fourth Amendment jurisprudence has traditionally focused on the officer's factual conclusions rather than understanding of the law. Expanding leeway allowed to police officers with respect to their factual assessment to the meaning of the laws they are meant to enforce runs the risk of eroding the Fourth Amendment's protections. In the absence of any evidence that holding police officers to this standard would prevent effective enforcement of the law, mistakes of law should not be considered reasonable under the Fourth Amendment.