California, United States of America
The following excerpt is from People v. White, B295147 (Cal. App. 2021):
unreasonable. (Heien, supra, 574 U.S. at p. 66.) However, "[t]he Fourth Amendment tolerates only reasonable mistakes, and those mistakeswhether of fact or of lawmust be objectively reasonable. We do not examine the subjective understanding of the particular officer involved. [Citation.]" (Ibid.; see People v. Campuzano (2015) 237 Cal.App.4th Supp. 14, 16 ["an objectively reasonable mistake of law can give rise to a reasonable suspicion under the Fourth Amendment"].)
In reviewing the trial court's denial of a motion to suppress, we defer to the trial court's factual findings where supported by substantial evidence. (See People v. Woods (1999) 21 Cal.4th 668, 673.) We review independently whether the search or seizure was legal under the Fourth Amendment requirement of reasonableness. (People v. Camacho (2000) 23 Cal.4th 824, 830-831.)
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