On appeal, the court first reviewed the Indiana statute on stop lamps. Applying the rule of statutory construction tat "[p]enal statutes should be construed strictly against the State and ambiguities should be resolved in favor of the accused.", it found that the statute only required one working tail lamp.
Then, it found that the officer's mistake of law (as opposed to mistake of fact) did not justify the stop of defendant's vehicle, and granted the motion to suppress, stating:
“Although a law enforcement officer's good faith belief that a person has committed a violation will justify a traffic stop, an officer's mistaken belief about what constitutes a violation does not amount to good faith. Such discretion is not constitutionally permissible.” State v. Rager, 883 N.E.2d 136, 139-40 (Ind.Ct.App.2008) (citations omitted); see also Meredith v. State, 906 N.E.2d 867, 870 (Ind.2009). As well as having a constitutional dimension, this limitation is one of common sense. While we as citizens desire and expect law enforcement officers to enforce the requirements of state statutes as they pertain to motor vehicles, if the condition of our motor vehicles clearly and visibly meets these requirements, we should not be subject to a traffic stop on suspicion of an alleged violation thereof. Because the condition of Goens's vehicle could not reasonably appear to violate applicable Indiana statutes at the time it was observed by Officer Lengerich, the vehicle's condition could not and did not support reasonable suspicion for the traffic stop. We therefore conclude that the trial court abused its discretion when it denied Goens's motion to
Note: Interestingly, the opinion acknowledged that federal law requires a vehicle of this nature to be equipped with 3 stop lamps. However, it did employ this regulation in interpreting their own state's statute......
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