United States v. Henry Stephens
2014 U.S. App. LEXIS 15920
| 4th Cir. | 2014Background
- Stephens convicted of illegal firearm possession; district court denied his suppression motion after GPS search; GPS device installed May 13, 2011 on Stephens’ vehicle without a warrant; officers tracked Stephens and searched his vehicle leading to a pistol discovery; Jones (2012) later held GPS tracking can be a search requiring warrant; Fourth Circuit applied good-faith exception based on binding appellate precedent (Knotts) as of 2011; Maryland law context supported reliance on Knotts pre-Jones; district court found suppression unnecessary due to good faith; Stephens appealed challenging the good-faith rationale and the classification of the search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the GPS search violated the Fourth Amendment. | Stephens | Geare/State | Unreasonable search under Fourth Amendment |
| Whether the exclusionary rule applies given good-faith reliance on precedent. | Stephens | State | Exclusionary rule does not apply if good-faith reliance on binding appellate precedent exists |
| Whether binding appellate precedent existed for warrantless GPS use in 2011 in the Fourth Circuit. | Stephens | State | Binding pre-Jones Knotts precedent existed and supported reliance |
Key Cases Cited
- Knotts v. United States, 460 U.S. 276 (1983) (GPS/beeper tracking not a Fourth Amendment search when movement is on public roads)
- Karo v. United States, 468 U.S. 705 (1984) (Beeper in container; tracking interior movements differs from public-road tracking)
- Jones v. United States, 132 S. Ct. 945 (2012) (GPS installation on vehicle treated as search; distinguish from Knotts/Karo)
- Davis v. United States, 131 S. Ct. 2419 (2011) (Good-faith exception when relying on binding appellate precedent)
- Krull v. United States, 480 U.S. 340 (1987) (Good-faith reliance on subsequently invalidated state statute)
- Maynard v. United States, 615 F.3d 544 (D.C. Cir. 2010) (GPS searches; pre-Jones decisions debated)
- Kelly v. State, 436 Md. 406 (Md. 2013) (Knotts binding appellate precedent in Maryland pre-Jones)
- United States v. Claridy, 601 F.3d 276 (4th Cir. 2010) (Joint federal-state HIDTA investigation; supra)
- United States v. Stone, 178 Md. App. 428 (Md. 2008) (GPS tracking upheld under pre-Jones Maryland law)
- United States v. Woodward, 546 F.2d 576 (4th Cir. 1976) (Early beeper cases in Fourth Circuit)
- United States v. Beilina, 665 F.2d 1335 (4th Cir. 1981) (Diminished expectation of privacy in vehicles)