United States v. Boyd – Case Brief Summary (Federal Court)

In United States v. Boyd, 692 F.Supp. 2d 594 (E.D. Va. 2010), the District Court for the Eastern District of Virginia concluded that the position taken by the majority of courts was the better view, stating, "the majority view more completely takes into account the purpose of the Fourth Amendment and decisions which animate it in the context of investigatory stops." 692 F.Supp. 2d at 600.

The court in Boyd predicted that the Fourth Circuit was likely to follow the majority view, and stated:

The Fourth Circuit has not addressed this issue. In United States v. McHugh, 349 Fed. Appx. 824, 2009 WL 3634278 (4th Cir. 2009), the Court of Appeals simply assumed that a stop based on a mistake of law is invalid. ("For purposes of our discussion, we assume, without deciding, that an officer's reasonable mistake of law may not provide the objective grounds for reasonable suspicion to justify a traffic stop.") However, the majority position is based on sound reasoning. Hence, it is likely that our Court of Appeals would hew to the majority rule. Under that precept, the officer's mistake of law renders the stop invalid, and the evidence recovered during the search of the defendant's person, the evidence obtained in the ensuing arrest, and his statements after that arrest must be suppressed under the exclusionary rule. (Id. at 600-01.)