763 S.E.2d 341
S.C.2014Background
- NCPD installed a GPS device on Adams' car without a warrant or authorization.
- GPS data indicated Adams traveled to Atlanta; upon return, officers arranged a planned traffic stop with a drug canine.
- The stop occurred near Charleston Southern University after Adams allegedly committed traffic violations.
- A canine sniff and pat-down led to discovery of 141.62 grams of cocaine; Adams was charged with trafficking and related offenses.
- Adams moved to suppress the seized drugs as fruits of an unlawful GPS installation and monitoring.
- Court of Appeals held Fourth Amendment violation but affirmed suppression not warranted due to attenuating intervening acts; SC Supreme Court reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Intervening acts dissolve taint test applicable? | Adams | Adams | Intervening acts doctrine rejected; taint not dissipated |
| Good-faith reliance on binding precedent can sustain warrantless GPS? | State | Adams | Rejected; Knotts/Karo not binding; statute requires warrant |
| Jones effect on suppression for GPS tracking? | State | Adams | Jones confirms search but cannot validate warrantless GPS here; suppression required |
Key Cases Cited
- Knotts v. United States, 460 U.S. 276 (U.S. 1983) (beeper surveillance; no expectation of privacy in moving vehicle)
- Karo v. United States, 468 U.S. 705 (U.S. 1984) (beeper installation in third-party container; distinguishes GPS context)
- Jones v. United States, 132 S. Ct. 945 (U.S. 2012) (GPS monitoring constitutes a search; trespass theory in focus)
- Nelson v. State, 336 S.C. 186, 519 S.E.2d 786 (S.C. 1999) (attenuation analysis for intervening events; distinguishable facts)
- United States v. Calandra, 414 U.S. 338 (U.S. 1974) (exclusionary rule deterrence; determines adoption of remedies)