Taillights and Motor Vehicle Stops: Part 2

The trial court granted defendant’s motion to suppress evidence resulting from the motor vehicle stop, but the court denied his motion to dismiss the indictment. On the motor vehicle stop, the trial court agreed with defendant that Officer Carletta’s understanding of the maintenance-of-lamps statute had been “incorrect” and that defendant had not violated the statute because he had at least one functioning taillight on each side of the vehicle. The court concluded that Officer Carletta’s erroneous interpretation of the law could not pass constitutional scrutiny.

The Appellate Division granted leave to appeal and reversed the trial court. Relying extensively on the 2014 United States Supreme Court case of Heien v. North Carolina, the panel determined that “even if the officer was mistaken that the inoperable tail light constituted a Title 39 violation, he had an objectively reasonable basis for stopping defendant’s vehicle.” In reaching that conclusion, the panel questioned the continuing vitality of the 2005 New Jersey Appellate Division case of State v. Puzio, which had held “that where an officer mistakenly believes that driving conduct constitutes a violation of the law, but in actuality it does not, no objectively reasonable basis exists upon which to justify a vehicle stop.” The panel went on to conclude that the statute at issue here was ambiguous and that even if Officer Carletta’s interpretation of the statute was an objectively reasonable mistake of law, the stop was permissible pursuant to Heien. The panel’s reasoning made it unnecessary to reach the State’s argument about the applicability of the community caretaking doctrine.

The “community caretaking” doctrine is a classic catch-all that the police and prosecutors often use in an effort to justify constitutional violations. The doctrine essentially says that if the police are not motivated by evidence-gathering at the time of a search or seizure, their conduct does not violate the constitution. The doctrine is at odds with case law holding that an officer’s subjective intent is irrelevant, and the focus of courts must be on the objective reasonableness of police action.