United States v. Baez
2012 WL 2914318
D. Mass.2012Background
- Baez is arrestee in a case where GPS tracking of his Chevrolet Caprice yielded key evidence.
- GPS monitoring occurred Aug 2009–Aug 2010; device sent alerts for travel outside Baez's residence perimeter.
- Evidence tied fires in April and July 2009 to Baez via surveillance and vehicle matching.
- ATF traced Caprices, cross-checking with Baez’s dental and auto body records; Baez matched distinctive car features.
- Warrants were executed for Baez’s vehicle and residence, yielding gasoline residues, matches, and laundry-tag evidence linking to arson.
- Baez moved to suppress arguing that Jones requires suppression, while the court applied Davis good-faith framework.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suppression is proper after Jones under Davis. | Baez. | Baez. | Suppression not required; good-faith exception applies. |
| Impact of circuit precedent when GPS tracking was widely accepted before Jones. | Baez | Baez | No suppression due to substantial consensus and lack of controlling contrary authority. |
| Effect of Maynard and unsettled law on the remedy for Fourth Amendment violations. | Baez | Baez | Remedy guided by Davis; does not retroactively suppress. |
Key Cases Cited
- United States v. Jones, 565 U.S. 400 (2012) (GPS monitoring constitutes a search; warrant required)
- Davis v. United States, 131 S. Ct. 2419 (2011) (exclusionary rule limited by good-faith reliance; deterrence balance)
- United States v. Maynard, 615 F.3d 544 (D.C. Cir. 2010) (circuit split on GPS tracking; later superseded by Jones)
- United States v. Marquez, 605 F.3d 604 (8th Cir. 2010) (early GPS tracking precedent favoring non-search)
- United States v. Pineda-Moreno, 591 F.3d 1212 (9th Cir. 2010) (GPS monitoring not a Fourth Amendment search)