by "Maxima Speed" (maximaspeed)
Published 12/07/2017 at 17:02
by "Maxima Speed" (maximaspeed)
Published 12/07/2017 at 17:02
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STARS: 2
Thought I would post a brief summary of an interesting Supreme Court case, which I had to write up for my Criminal Law class.
Heien v. North Carolina US 574 U.S. (2014)
Facts:
On April 29th, 2009, Nicholas Heien was arrested after being found in possession of cocaine during a traffic stop. The traffic stop had been initiated by Sergeant Darisse of the Surry County Sheriffs department, North Carolina, due to a non-functional brake light. Sergeant Darisse pulled over the defendant who was a passenger in his own vehicle, being driven by Maynor Javier Vasquez. During the conversation with the defendants, Sergeant Darisse noted that that Mr. Heien was acting nervous, the deputy upon asking the driver for permission to search the vehicle but was directed to ask Mr. Heien (the owner). The defendant said that he, quote “didn’t really care” and the officer searched the vehicle, finding a quantity of cocaine.
Mr. Heien and Mr. Vasquez were then arrested and charged with cocaine trafficking. Mr. Heien file a motion to suppress the results of the search, due to the wording of North Carolina law, which does not require multiple working brake lights. Therefore claiming that the brake light failure was not reasonable grounds for search and seizure. Sergeant Darisse was not aware that the law did not require all equipped brake lights to be functional on a motor vehicle. The court denied the motion and Mr Heien pled guilty but reserved his right to appeal the motion to suppress. The trial courts decision was reversed by the North Carolina Court of Appeals, but then upheld by the North Carolina Supreme Court when appealed by the State of North Carolina. Mr. Heien then filed a writ of certiorari, for the U.S. Supreme Court to hear the case.
Issue:
Is evidence of a crime, gained by a law enforcement officers misunderstanding of the written law, protected under 4th amendment of the constitution, which, guarantees freedom from unreasonable search and seizure.
Holding:
No, evidence of a crime is not protected under the 4th amendment, with the condition that the law enforcement officer has made a reasonable misinterpretation of the written law.
Rule:
The Supreme Court upheld the trail courts denial of suppression, overturning the the decision of the North Carolina Supreme Court. Law enforcement can seize evidence of a crime during a traffic stop even if the traffic stop was initiated due to a reasonable misunderstanding of the written law, but not due to ignorance of the law.
Rationale:
The Court found in a an 8-1 majority that due to the unclear wording of the North Carolina automotive brake light and taillight code, and that the law enforcement officer was duly knowledgable of the law, the evidence would still be permissible even had Mr. Heien not given permission to search the vehicle. This is because an objectively reasonable misinterpretation not incompatible with reasonable, individual suspicion, required by the 4th Amendment. This ruling does not permit violation of the 4th amendment due ignorance of the law, or sloppy police work. The one dissenting vote maintained that the interpretation of the 4th amendment should revolve solely around the facts of the law not interpretation, however the Court deemed that the burden of proof to assert reasonable misunderstanding is so high that it did not represent a threat to erode the 4th amendments protections.
"Chariotoflove" (chariotoflove)
12/07/2017 at 17:24, STARS: 1
I think you meant to write the Supreme Court upheld the state supreme courts agreement with the trial court, based on my reading.
"Maxima Speed" (maximaspeed)
12/07/2017 at 17:28, STARS: 1
True, I forgot to edit that in the one I just turned in. Also mis spelled trial.
"DC3 LS, will be perpetually replacing cars until the end of time" (dc3ls-)
12/07/2017 at 17:30, STARS: 2
I wonder if the misunderstanding of the brake light law was due to, WANT OF A COMMA!
"Maxima Speed" (maximaspeed)
12/07/2017 at 17:32, STARS: 0
Oh boy........ I knew this was a mistake. To be fair I forgot I had to do it and had 30 minutes to whip it up before the deadline.
"Rainbow" (rainbeaux)
12/07/2017 at 17:43, STARS: 2
I gotta side with the dissenting vote here. The cop was wrong, period. This opens the door for all sorts of misinterpretations to be treated as fact.
Also, fun fact: the one time I had my car searched, I was also pulled over for a 3rd brake light. They didn’t find anything, obviously. Just saw an out-of-county license plate in a college town, driving away from a liquor store at night. The cop was so cocky and confident that I bought alcohol with a fake ID, so watching him open my empty trunk was extremely satisfying.
"Textured Soy Protein" (texturedsoyprotein)
12/07/2017 at 17:43, STARS: 1
Remember to cite your sources!
"Future next gen S2000 owner" (future-next-gen-s2000-owner)
12/07/2017 at 17:45, STARS: 1
Lawyers are awful. They make everything so complex nobody can understand what they are trying to say.
"Maxima Speed" (maximaspeed)
12/07/2017 at 17:48, STARS: 0
For this specific paper we don’t have to cite sources, per the teacher.
"RPM esq." (rpm3)
12/07/2017 at 18:04, STARS: 0
That’s how you can tell a lawyer is bad at their job (assuming you’re their client). Good lawyers make complicated concepts seem clear and simple, which is considerably more difficult than making simple concepts complicated.
"diplodicus forgot his password" (diplodicusforgothispassword)
12/07/2017 at 18:09, STARS: 2
Moral of the story is don’t consent to searches without a warrant even if you have nothing to hide. I let the cops search me a few times when I was a teenager and got let go. But after seeing what they’ll do to a car if they really think you have some shit it’s a no from me no matter what. They will fuck your shit up and then just leave when they don’t find what they want, or take you to jail if they do. Not to mention the civil asset forfeiture bullshit they can pull if they want.
"RPM esq." (rpm3)
12/07/2017 at 19:12, STARS: 0
What level class is this for?
"Maxima Speed" (maximaspeed)
12/07/2017 at 19:16, STARS: 0
Introductory course at a community college. The course name is just Criminal Law.
"RPM esq." (rpm3)
12/07/2017 at 20:08, STARS: 1
In that case, nice job summarizing the procedural history, identifying the main legal issues, and explaining the court’s reasoning. Proofread the next one, though.
"Maxima Speed" (maximaspeed)
12/07/2017 at 20:38, STARS: 1
For sure, I made a much better one on lochner v New York about 2 months ago, this one I got done and turned it in with 2minutes to spare because I forgot it was due.
"RPM esq." (rpm3)
12/07/2017 at 20:48, STARS: 0
Been there.