State v. Johnson (Slip Opinion), 22 N.E.3d 1061

Johnson was convicted of trafficking and possession of cocaine after police attached a GPS device to his van in October 2008 without a warrant.
Detective Hackney relied on binding appellate precedent (Knotts and Karo) and advice from prosecutors and colleagues to believe no warrant was required.
GPS tracking continued for five days, leading to surveillance that culminated in Johnson’s associate’s arrest and seizure of seven kilograms of cocaine.
After remand following Jones (2012), the trial court initially suppressed but then admitted the GPS-derived evidence under the good-faith exception.
The Twelfth District affirmed, applying a case-by-case good-faith analysis based on the pre-Jones landscape and Knotts/Karo precedent.
This appeal asks whether the good-faith exception applies when the controlling law changed after the police relied on binding but later-overruled precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the good-faith exception apply to GPS tracking based on binding precedent pre-Jones?	Johnson	Johnson	Yes; good-faith exception applies
Was Hackney’s belief in the legality of GPS placement objectively reasonable?	Johnson	Johnson	Yes; belief was objectively reasonable
Did Jones overrule Knotts and Karo to foreclose the good-faith defense here?	Johnson	Johnson	No; pre-Jones precedent supported good faith at the time

United States v. Knotts, 460 U.S. 276 (1983) (tracking beeper on public movements not a search)
United States v. Karo, 468 U.S. 705 (1984) (monitoring interior of premises may require a warrant; trespass concept evolves)
Jones v. United States, 132 S. Ct. 945 (2012) (GPS attachment to a vehicle is a search under the Fourth Amendment)
Davis v. United States, 131 S. Ct. 2419 (2011) (good-faith reliance on binding appellate precedent can negate exclusion)
Weeks v. United States, 232 U.S. 383 (1914) (exclusionary rule origins and deterrence purpose)