United States v. Jones
132 S. Ct. 945
| SCOTUS | 2012Background
- Jones, a nightclub owner, was under narcotics-trafficking suspicion by a joint FBI/MPD task force.
- Investigators employed surveillance, a club front-door camera, pen register, and wiretap to build evidence.
- A warrant authorized GPS on a Jeep registered to Jones’s wife, to install in DC within 10 days.
- Agents installed the GPS on the Jeep in Maryland, 11th day, and tracked movements for 28 days, relaying data.
- A later trial used GPS data to convict Jones; on appeal, lower court barred some data as 4th Amendment violation, leading to Supreme Court review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GPS attachment and monitoring constitutes a Fourth Amendment search. | Jones argues a search occurs due to trespass and information gathering. | Government contends no search under Katz, focusing on privacy expectations. | Yes; GPS attachment and monitoring is a Fourth Amendment search. |
| Whether the case should be governed by trespass-based theory or Katz privacy standard. | Jones relies on traditional trespass/physical intrusion to protect privacy. | Government argues Katz privacy framework suffices. | Court adopts a mixed approach; physical intrusion combined with information gathering triggers a search. |
| Do Knotts/Karo beeper cases control GPS surveillance analysis? | Knotts/Karo do not control long-term GPS tracking. | Beepers show limited/public information; not controlling for GPS here. | Knotts/Karo do not foreclose GPS surveillance analysis; GPS tracking can be a search. |
| Is four weeks of GPS monitoring permissible without a warrant? | Prolonged monitoring invades reasonable privacy expectations. | Surveillance may be permissible under Katz for shorter terms. | Long-term GPS monitoring constitutes a Fourth Amendment search; warrant required for such intrusions. |
| Was the Government’s forfeiture/alternative argument about probable cause preserved? | Arguably raised; not preserved below. | Government contends argument forfeited. | Argument forfeited; court did not resolve on this basis. |
Key Cases Cited
- Knotts v. United States, 460 U.S. 276 (1983) (beeper monitoring of vehicle on public roads; public information; limited privacy expectation)
- Karo v. United States, 468 U.S. 705 (1984) (beeper in container; consent of original owner; no invasion of privacy at that time)
- Katz v. United States, 389 U.S. 347 (1967) (privacy protected persons, not places; Katz approach supplemented trespass test)
- Oliver v. United States, 466 U.S. 170 (1984) (open fields doctrine; trespass alone not always a search)
- Alderman v. United States, 394 U.S. 165 (1969) (homeowners’ privacy in conversations under their roof)