Background
Thomas Jorge Finch entered a conditional guilty plea to conspiracy to transport illegal aliens. He preserved his right to appeal the denial of his motion to suppress evidence derived from a traffic stop.
An officer stopped Finch’s vehicle after concluding that Finch had failed to use a turn signal. Finch argued that the stop was unlawful because the officer misinterpreted Texas Transportation Code § 545.104(a), which requires drivers to signal an intention to change lanes.
The Court’s Holding
The Fifth Circuit affirmed the denial of Finch’s suppression motion. A traffic stop is justified at its inception when an officer has objectively reasonable suspicion that a traffic violation occurred or is about to occur.
The court concluded that Texas courts had not rejected the officer’s interpretation of the turn-signal statute. Thus, even if the officer misunderstood the statute, that mistake of law was objectively reasonable and could support the stop under Heien v. North Carolina.
Key Takeaways
- An objectively reasonable mistake of law may provide the reasonable suspicion needed for a traffic stop.
- Texas law requires a driver to signal an intention to change lanes.
- Because Texas courts had not rejected the officer’s interpretation of the statute, suppression was unwarranted.
Why It Matters
The decision applies the Supreme Court’s reasonable-mistake-of-law doctrine to a stop based on Texas turn-signal requirements. A defendant cannot obtain suppression merely by showing that an officer’s interpretation may have been mistaken; the relevant question is whether that interpretation was objectively reasonable.