Mistaken interpretation of law by officer created reasonable suspicion

March 24, 2015

The Indiana Court of Appeals reversed its earlier reversal of a trial court ruling after the Supreme Court of the United States found that reasonable mistakes of law do not violate the Fourth Amendment.

In December 2014, the COA tossed Kolyann Williams’ conviction for Class A misdemeanor marijuana possession in Williams v. State, 22, N.E.3d 730 (Ind. Ct. App. 2014). The unanimous panel held that evidence supporting the conviction was gathered as a result of an illegal traffic stop.

Kokomo police officer Jeff Packard made the stop after he noticed one of the brake lamps on Williams’ vehicle had a hole in it and was emitting more white light than red. However, the Court of Appeals ruled under the plain language of Indiana Code 9-16-6-4 a broken tail lamp does not violate state law as long as some red light is plainly visible from at least two rear lights.

The State of Indiana petitioned for a rehearing, arguing the U.S. Supreme Court decision in Heien v. N. Carolina 135 S. Ct. 530 (2014) requires a different result. Here, the justices found in an 8-1 decision that law enforcement does not have to know the full scope of the state statute to justify a traffic stop. If the mistaken interpretation of the law is reasonable, then there exists reasonable suspicion under the Fourth Amendment.

Finding its original disposition is no longer good law, the Court of Appeals reversed its earlier decision and affirmed the judgment of the trial court in Koylann Williams v. State of Indiana, 34A02-1406-CR-418.
“In conclusion, while we agree that Williams was committing no infraction at the time he was stopped by Officer Packard, Officer Packard had a reasonable belief that he was, thereby justifying the stop,” Judge Cale Bradford wrote for the court. “Consequently, the evidence seized as a result of the stop need not be suppressed.”



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