United States v. Amaya
853 F. Supp. 2d 818
N.D. Iowa2012Background
- Amaya moved to suppress GPS-derived evidence from three vehicles (Yukon, Maxima, Murano) and the government’s use of GPS surveillance without a warrant; Jones later held GPS monitoring is a search, but the court invokes the good-faith exception under Davis to avoid suppression if binding precedent supported warrantless GPS use.
- GPS devices were attached to nine vehicles across the investigation, including Amaya’s primary vehicle (Yukon) and two other vehicles, with devices on outside of vehicles and pinging at 15-second intervals to a server.
- Initial mistrials occurred (first witness reference to sealed in limine material; December 2011 mistrial after discovery issues), followed by a second mistrial in January 2012 when GPS use came to light; Jones (2012) announced GPS as a search, prompting suppression motions; discovery file failed to disclose GPS usage and relevant affidavit.
- The defense raised that discovery violations tainted the proceedings, and Amaya sought suppression or dismissal; the court analyzed Fourth Amendment applicability and discovery sanctions under Davis and Pherigo, ultimately denying suppression while planning sanctions adjudication.
- The court determined Marquez was binding precedent at the time GPS monitoring occurred, and that the officers acted in reasonable reliance on that precedent, leading to a denial of suppression under the good-faith exception.
- Following post-hearing proceedings, a subsequent memorandum on sanctions found no bad faith or required sanctions, though a sanctions hearing was held to consider milder remedial measures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fourth Amendment scope of GPS surveillance | Amaya: GPS monitoring violated the Fourth Amendment as a search | Government: Jones creates a search but good-faith reliance on binding precedent (Marquez) saves evidence | No suppression; good-faith exception applies; binding precedent supported admissibility |
| Discovery violations and sanctions | Amaya: GPS usage not disclosed violated discovery; sanctions warranted | Government: no severe sanctions warranted; remedial measures suffice | Suppression denied; sanctions hearing set; no extreme sanctions imposed |
| Binding precedent and reliance standard for GPS rulings | Amaya argues Marquez is not controlling due to standing or trespass nuances | Government: Marquez binding; officers reasonably relied on it | Marquez binding at time of GPS use; reliance was objectively reasonable; exclusionary rule not triggered |
| Waiver and scope of warrantless searches of Maxima | Amaya contends warrantless search of Maxima was impermissible | Government/Amaya had notice; waiver applies; search within scope of prior notice | Argument deemed waived as to warrantless Maxima search; not considered further |
Key Cases Cited
- United States v. Jones, 132 S. Ct. 945 (Supreme Court 2012) (GPS monitoring constitutes a search; good-faith reliance governs evidence admissibility)
- United States v. Marquez, 605 F.3d 604 (8th Cir. 2010) (binding precedent: warrantless noninvasive GPS monitoring with reasonable suspicion permissible for a reasonable period)
- Knotts, 460 U.S. 276 (Supreme Court 1983) (beeper surveillance did not invade privacy; GPS not resolved in Knotts)
- Davis v. United States, 131 S. Ct. 2419 (Supreme Court 2011) (good faith exception for reliance on binding appellate precedent)
- United States v. Barragan, 379 F.3d 524 (8th Cir. 2004) (standing and alternative rationale for Fourth Amendment challenges)