United States v. Hunt, 1:20-cr-10119

Background

In March 2019 Hunt was released on $15,000 bail in Suffolk Superior Court with GPS electronic monitoring and home confinement as conditions; he signed an Order acknowledging GPS coordinates are recorded and "are not private and confidential."
After posting bail in July 2019 Hunt met with probation, signed GPS supervision terms, and later sought and obtained curfew modifications (in August and October 2019), relying on GPS monitoring to account for his whereabouts.
The FBI investigated alleged drug trafficking by Hunt and co-defendant Brewster and conducted controlled buys on February 26 and March 2, 2020; agents tied a rented Chevrolet Malibu to Hunt and observed transactions consistent with distribution.
On May 8–9, 2020 an FBI agent requested limited historical GPS points from Massachusetts Probation for two narrow 1.5‑hour windows on the controlled‑buy dates; the agent did not obtain a warrant and received maps showing Hunt’s locations.
A federal indictment charged Hunt with drug distribution offenses; Hunt moved to suppress the GPS data. Judge Casper denied the suppression motion.

Issues

Issue	Plaintiff's Argument (United States)	Defendant's Argument (Hunt)	Held
Whether attachment of GPS bracelet or obtaining limited historical GPS data was a Fourth Amendment search	No — Hunt had no reasonable expectation of privacy in GPS monitoring imposed as a release condition and in the limited historical points obtained	Yes — GPS location monitoring and historical location data implicate privacy rights (relying on Carpenter) and constitute a search	Court: Not a Fourth Amendment search on this record; alternatively, even if a search, it was reasonable given consent and circumstances
Whether Hunt validly consented to GPS monitoring and sharing of GPS data	The Order, Hunt’s counsel offering GPS as part of release strategy, and Hunt’s subsequent curfew requests show voluntary, knowing consent	Hunt says he did not read fine print, believed GPS was only to ensure home confinement and court appearance, and that consent was coerced by the choice of release vs. continued detention	Court: Consent was freely and voluntarily given under the totality of circumstances
If a search, whether its scope was reasonable under the Fourth Amendment	The limited temporal scope (1.5 hours on two dates) and Hunt’s diminished privacy on pretrial release make the search reasonable to enforce release conditions and prevent new crimes	The search intruded on privacy; Carpenter suggests broader protections for location data	Court: The intrusion was limited and outweighed by government interests; search (if one) was reasonable in scope
Whether suppression is barred by a good‑faith/Leon exception even if a Fourth Amendment violation occurred	Agents reasonably and objectively relied on absence of controlling law requiring a warrant for such limited GPS points and therefore acted in good faith	Even if reliance was objectively reasonable, the underlying acquisition violated Hunt’s rights and suppression is required	Court: Exclusionary rule not warranted — agents acted in objectively reasonable good faith, so suppression would not be appropriate

Key Cases Cited

Smith v. Maryland, 442 U.S. 735 (1979) (third‑party doctrine and expectation‑of‑privacy framework)
Carpenter v. United States, 138 S. Ct. 2206 (2018) (accessing multi‑day historical cell‑site location information constituted a search)
Riley v. California, 573 U.S. 373 (2014) (warrant requirement and exceptions framework)
United States v. Leon, 468 U.S. 897 (1984) (good‑faith exception to exclusionary rule)
Davis v. United States, 564 U.S. 229 (2011) (reasonable reliance on binding precedent can bar suppression)
Samson v. California, 547 U.S. 843 (2006) (balancing intrusion against government interest for searches of supervised individuals)
United States v. Knights, 534 U.S. 112 (2001) (reasonableness of searches of probationers)
United States v. Coombs, 857 F.3d 439 (1st Cir. 2017) (consent as exception to warrant requirement; totality‑of‑circumstances)
United States v. Twomey, 884 F.2d 46 (1st Cir. 1989) (evaluating voluntariness of consent)
Commonwealth v. Norman, 484 Mass. 330 (2020) (Mass. SJC decision addressing consent to GPS conditions in pretrial release)