D.Kan.: Heien relieves a federal court of having to make fine distinctions about whether state traffic law was validated

Heien relieves a federal court of having to make fine distinctions about whether state traffic law was validated: The question is whether the officer’s view was reasonable. [Again, close enough for government work.] United States v. Morales, 2015 U.S. Dist. LEXIS 80838 (D.Kan. June 23, 2015):

It is not necessary for this federal court to interpret state traffic law in this case. That’s because even if the officer was mistaken about the law, the stop was still lawful under recent Supreme Court precedent. In Heien v. North Carolina, the Supreme Court held that a federal court is not required to suppress evidence gathered during a traffic stop that was the result of an officer’s mistaken belief about a traffic law. In that case, an officer stopped a driver because only one of the vehicle’s two brake lights was working, and the stop led to evidence that supported a conviction for cocaine trafficking. The state appeals court held that the stop was based on the officer’s erroneous understanding of state law because the state statute only required one brake light, not two as the officer believed. The state supreme court upheld the stop because the officer’s mistaken understanding of the law was reasonable, and the U.S. Supreme Court agreed. In Heien, the U.S. Supreme Court held that reasonable suspicion may be based on a reasonable mistake of law. The Court explained that to be reasonable is not to be perfect, so the Fourth Amendment allows for some mistakes on the part of law enforcement officers. A mistake of law must be objectively reasonable, which means that the Court does not examine the subjective understanding of the particular officer involved.

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