Unreported / Non-Citable
Background
Thomas Jorge Finch entered a conditional guilty plea to conspiracy to transport illegal aliens. He reserved the right to appeal the denial of his motion to suppress evidence derived from a police officer’s stop of his vehicle for failing to use a turn signal.
Finch argued that the stop was not justified because the officer misinterpreted Texas Transportation Code § 545.104(a), which requires a driver to signal an intention to change lanes. The district court denied the suppression motion, and Finch appealed.
The Court’s Holding
The Fifth Circuit affirmed. A traffic stop is justified at its inception when an officer has objectively reasonable suspicion that illegal activity, including a traffic violation, occurred or was about to occur. The court concluded that Texas courts had not rejected the officer’s interpretation of the turn-signal statute.
Even assuming the officer misunderstood the statute, the court held that the mistake of law was objectively reasonable under Heien v. North Carolina. The stop was therefore lawful, and the district court properly denied Finch’s motion to suppress.
Key Takeaways
- An objectively reasonable suspicion of a traffic violation can justify a vehicle stop.
- A reasonable mistake about the meaning of a traffic law does not necessarily invalidate a stop under the Fourth Amendment.
- Because Texas courts had not rejected the officer’s interpretation of the turn-signal statute, the officer’s reliance on that interpretation was objectively reasonable.
Why It Matters
The decision applies the Supreme Court’s reasonable-mistake-of-law doctrine to Texas’s lane-change signaling requirement. It confirms that evidence need not be suppressed merely because the traffic stop rested on a potentially mistaken legal interpretation, so long as that interpretation was objectively reasonable.