See United States v. King, 244 F.3d 736, 739 (9th Cir. 2001) (indicating that when "`an officer makes a traffic stop based on a mistake of law, the stop violates the Fourth Amendment.'" (quoting United States v. Twilley, 222 F.3d 1092, 1096 (9th Cir. 2000))); United States v. Ramirez, 115 F. Supp.2d 918, 922 (W.D. Tenn. 2000) (finding "there is no good faith exception to warrantless stops"); Hameen v. State, 541 S.E.2d 668, 669 (Ga.Ct.App. 2000) (holding that ignorance of the law is no excuse). It is important to note there is a distinction between a mistake of law and a mistake of fact. Whren requires the officer have probable cause to believe the traffic law is being violated.
The officers therefore had reasonable suspicion to believe that Thomas's vehicle was being operated in violation of state law. See United States v. Moreno, 43 F. App'x 760, 766 (6th Cir. 2002)(holding that police had reasonable suspicion that the defendant's windows violated the law even though the officer was confused "about the origin of the law which he was enforcing — that is, whether it was a state statute or a municipal ordinance"); United States v. Ramirez, 115 F. Supp. 2d 918, 922-23 (W.D. Tenn. 2000)(stating that the officer's "befuddlement as to whether the Memphis ordinance was identical to the state statute does not deprive the stop of probable cause"); see also Hughes, 606 F.3d at 316 (stating that a police officer must reasonably believe that the driver of the car is violating the law but need not be able to cite the particular statute or municipal code in order for the stop to be permissible). For the foregoing reasons, the officers had developed a reasonable articulable suspicion to stop Thomas for committing two distinct traffic law violations.