The decision in People v. Guthrie,1 a constitutional stop case recently decided by the New York State Court of Appeals, held that mistakes of law by police in New York can provide the basis for a valid traffic stop so long as the mistake is objectively reasonable.

The brief factual matrix of Guthrie can be stated as follows: The arresting officer stopped the defendant’s vehicle after observing it drive through a stop sign located at the edge of a supermarket parking lot as the vehicle was exiting onto a public street in Wayne County. During the stop, the officer smelled a strong odor of alcohol, and the defendant was arrested.

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