United States v. Castetter, 115 F. Supp. 3d 968

Defendant lived at a one‑story home in Kimmell, Indiana; investigators suspected him of supplying methamphetamine.
Michigan authorities obtained a 90‑day warrant to install and monitor a GPS unit on a 1998 Ford Crown Victoria registered to Holst and Hollister; GPS recorded trips to Defendant’s address on Aug 30 and Sept 4, 2014.
Michigan tracked the vehicle to Defendant’s residence (showing arrival times and duration), later stopped the car in Michigan and seized methamphetamine from Holst when the car returned.
DEA Task Force Officer Lundy used information from Michigan (informant + GPS data) and a cooperating witness to obtain a state search warrant for Defendant’s home; search yielded methamphetamine, syringes, and cash.
Defendant moved to suppress and to dismiss, arguing GPS monitoring was a warrantless electronic search of his home that provided the sole basis for the house warrant (fruit of the poisonous tree); government argued no search of Defendant’s home occurred and Defendant lacked standing to challenge GPS tracking of another’s car.
Court held an evidentiary hearing, found Defendant has standing to challenge an alleged search of his home, and denied the motion to suppress/dismiss, concluding GPS monitoring did not violate Fourth Amendment rights as applied here.

Issue	Defendant's Argument	Government's Argument	Held
Whether GPS monitoring of another’s car that showed location and duration at Defendant’s address constituted a Fourth Amendment "search" of Defendant’s home	GPS monitoring revealed who was inside and how long, thus electronically searching the home without a warrant (invoking Karo/Kyllo)	GPS data only showed location/duration visible from public vantage; it did not reveal interior details or identity of occupants, so no search occurred	Court: No search of the home — GPS revealed only location/duration information that could have been obtained by visual surveillance, so Fourth Amendment not infringed
Whether Defendant has standing to challenge the alleged warrantless electronic search of his home	Defendant has a reasonable expectation of privacy in his home and may challenge searches of it	Government argued lack of standing to challenge GPS placed on another’s vehicle	Court: Defendant has standing to challenge an alleged search of his own home; standing argument moot because Court found no search occurred
Whether evidence should be suppressed as fruit of the poisonous tree if GPS monitoring was illegal	If GPS monitoring was an illegal search that provided the sole basis for the home warrant, all fruits must be suppressed	Government: GPS monitoring lawful or did not implicate Defendant’s privacy; denial of suppression justified	Court: Suppression denied because there was no Fourth Amendment search by GPS monitoring

Katz v. United States, 389 U.S. 347 (establishes reasonable expectation of privacy test)
United States v. Karo, 468 U.S. 705 (warrantless monitoring of beeper inside a home can be a Fourth Amendment search)
United States v. Knotts, 460 U.S. 276 (beeper monitoring on public roads not a search where information observable from public vantage)
Kyllo v. United States, 533 U.S. 27 (use of sense‑enhancing technology to obtain interior details is a search)
United States v. Jones, 565 U.S. 400 (attachment of GPS to vehicle implicates Fourth Amendment principles)
Davis v. United States, 564 U.S. 229 (explains exclusionary rule as remedy for Fourth Amendment violations)
Segura v. United States, 468 U.S. 796 (fruit of the poisonous tree and suppression principles)
Rakas v. Illinois, 439 U.S. 128 (standing requires legitimate expectation of privacy)
Minnesota v. Carter, 525 U.S. 83 (source of privacy expectations outside Fourth Amendment)
United States v. Scott, 731 F.3d 659 (7th Cir. 2013) (party seeking suppression must show a reasonable expectation of privacy)