Police Officer's Mistake of Law Case In California

In People v. Glick (1988), a six-year veteran officer detained a car on the grounds its New Jersey license plates did not display registration tags because he believed New Jersey, like California, required registration stickers. The officer had previously stopped at least 75 out-of-state cars from nine states for faulty registration, every one of which require registration stickers on license plates. (Glick, supra, 203 Cal. App. 3d at pp. 799, 803.) New Jersey does not require such stickers. The court concluded the officer's mistake of law was reasonable: an officer cannot realistically be expected to know the registration laws of all 50 states; proportionally few New Jersey vehicles visit California; this officer had never before encountered a New Jersey vehicle; and in his experience the statutes of other states comport with California's. We noted, however, that a different outcome might be required were the vehicle from a contiguous state or if that state's motorists routinely drove on California roads, e.g., a highway patrol officer posted in the Lake Tahoe area would reasonably be expected to be familiar with Nevada registration laws. (Glick, 203 Cal. App. 3d at pp. 803-804.)