United States v. Edgar Barraza-Maldonado
2013 U.S. App. LEXIS 20690
| 8th Cir. | 2013Background
- DEA agents attached a GPS device to Barraza-Maldonado's car in a Phoenix public lot without a warrant, relying on Ninth Circuit precedent at the time.
- Barraza-Maldonado borrowed the car and drove it from Arizona to Minnesota, while agents monitored its movements via GPS.
- The car was stopped in Minnesota for two traffic violations; its occupants lacked valid licenses, and the car was towed.
- A drug-detection dog alerted to narcotics; a search of the car uncovered a large quantity of cocaine in the spare tire compartment.
- Barraza-Maldonado moved to suppress the evidence, arguing Fourth Amendment violation under Jones; the district court denied the motion.
- The district court held that even if Sixth Amendment reliance on Jones were implicated, suppression was not warranted because of the good-faith exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether good-faith exception applies to GPS monitoring | Barraza-Maldonado argues reliance on unsettled law undermines reasonableness. | Barraza-Maldonado relies on the government’s position that officers followed binding Ninth Circuit precedent. | Yes; the good-faith exception applies. |
Key Cases Cited
- Davis v. United States, 131 S. Ct. 2419 (2011) (exclusionary rule does not apply when police rely on binding appellate precedent)
- United States v. Leon, 468 U.S. 897 (1984) (good-faith standard for objectively reasonable reliance)
- United States v. Pineda-Moreno, 591 F.3d 1212 (9th Cir. 2010) (GPS installation not a search when no privacy expectation exists in car location)
- Knotts, 460 U.S. 276 (1983) (monitoring a car on public highways yields no reasonable expectation of privacy)
- Andres, 703 F.3d 828 (5th Cir. 2013) (circuit split on GPS good-faith reliance; relevant to approach)
- Marquez, 605 F.3d 604 (8th Cir. 2010) (precedent consistency related to location monitoring)
- Sparks, 711 F.3d 58 (1st Cir. 2013) (good-faith reliance when precedent exists in controlling circuit)
- United States v. Howard, 532 F.3d 755 (8th Cir. 2008) (Fourth Amendment analysis relevant to tracking in public space)