United States v. Harry Katzin
2013 U.S. App. LEXIS 21377
| 3rd Cir. | 2013Background
- Government installed a GPS device on Katzin’s van without a warrant to track movements.
- Katzin and his brothers moved to suppress, arguing Fourth Amendment violation and standing.
- Court reviews GPS searches, including whether warrant is required and applicability of good-faith doctrine.
- Series of prior cases criticized as beeper/GPS precedent; Jones later held GPS attachment is a search requiring a warrant.
- District Court suppressed all evidence; issue on standing resolved in favor of Katzin brothers; appeal followed.
- Court discusses bifurcation of GPS installation vs. monitoring, and the deterrence rationale for exclusionary rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Warrant requirement for GPS attachment | Katzin argues warrant is required for GPS attach. | Government contends no warrant is needed for installation. | Warrant required for GPS attachment. |
| Applicability of good-faith exception | Exclusionary rule should apply due to unsettled pre-Jones law. | Good faith should apply based on Knotts/Karo and out-of-circuit precedent. | Good-faith exception does not apply; suppression affirmed. |
| Standing of Katzin brothers | All three brothers were illegally seized and have standing. | Passengers generally lack standing in vehicle searches. | All three Katzin brothers have standing; suppression affirmed for all. |
| Automobile exception applicability | Automobile exception could excuse warrantless search due to vehicle mobility. | GPS tracking is distinct and not within the automobile exception. | Automobile exception does not justify GPS surveillance; warrant required. |
| Deterrence rationale for exclusion | Exclusion is too harsh and deters law enforcement. | Exclusionary rule deters unconstitutional practices. | Deterrence favors exclusion; suppression upheld. |
Key Cases Cited
- United States v. Knotts, 460 U.S. 276 (1983) (Beepers/gps movements on public roads; no privacy interest in movements)
- United States v. Karo, 468 U.S. 705 (1984) (Beeper surveillance inside containers; privacy implications when in private spaces)
- United States v. Maynard, 615 F.3d 544 (D.C. Cir. 2010) (Prolonged GPS surveillance deemed a search; warrant required)
- United States v. Jones, 131 S. Ct. 3064 (2011) (GPS device attachment constitutes a Fourth Amendment search)
- United States v. Mosley, 454 F.3d 249 (2006) (Single-incident approach to traffic stops; application to standing analysis)