The Supreme Court reasoned that a mistake of fact as to the authority of a person to give valid consent to entry and search does not invalidate the officers' actions, if the mistake was reasonable. In summary, the court said that "'Reasonableness' does not demand that the government be factually correct. We have not held that the Fourth Amendment requires factual accuracy. If the facts available to the officers would justify a belief that the consenting party had authority over the premises, the search is valid.”
Heien V. North Carolina (2014)
The preceding cases fall into a legal category called "mistake of fact" cases. But what if you've made a mistake of law? Until recently, many state and federal courts had ruled that since officers must be presumed to know the laws they are sworn to enforce, a search or seizure based on an officer's reasonable "mistake of law" would still be an unreasonable search or seizure. Appellate decisions in the 5th, 7th, 9th, 10th and 11th Circuits and in numerous state courts ruled that no matter how reasonable, mistakes of law could not support detentions, arrests, or searches. (The 8th Circuit held to the contrary.) The Supreme Court has now held that actions based on reasonable mistakes of law do not violate the Fourth Amendment.
Nicholas Heien was traveling through North Carolina in a vehicle that had only one working brake light. The vehicle was stopped by a deputy sheriff, who believed that state law required at least two brake lights. A consent search yielded enough cocaine to charge Heien with trafficking, and he moved to suppress. The state appeals court interpreted the statute as requiring only a single working brake light, found the stop to have been based on a mistake of law, and ordered the evidence suppressed. After the North Carolina Supreme Court reversed this ruling, Heien appealed to the U.S. Supreme Court, which said the following.
"To be reasonable is not to be perfect, and so the Fourth Amendment allows for some mistakes on the part of government officials, giving them fair leeway for enforcing the law in the community's protection. We have recognized that searches and seizures based on mistakes of fact can be reasonable. But reasonable men make mistakes of law, too, and such mistakes are no less compatible with the concept of reasonable suspicion. Reasonable suspicion arises from the combination of an officer's understanding of the facts and his understanding of the relevant law. The officer may be reasonably mistaken on either ground. It was objectively reasonable for an officer to think that Heien's faulty right brake light was a violation of North Carolina law. Because the mistake of law was reasonable, there was reasonable suspicion justifying the stop."