United States v. Jones
2012 U.S. Dist. LEXIS 177294
D.C. Cir.2012Background
- Jones’ conviction was vacated by the Supreme Court in 2012 after GPS tracking raised Fourth Amendment questions.
- Defendant Jones moves to suppress four months of cell-site data obtained under three magistrate orders in 2005.
- The government sought prospective cell-site information from Cingular Wireless for two numbers under the Stored Communications Act (SCA) and related orders.
- The three orders (June, August, September 2005) authorized disclosure for a 60-day period each, yielding four months of data (June 23–Oct 31, 2005).
- Defendant asserts the data collection violated the Fourth Amendment and that the SCA provides no suppression remedy; the government contends good-faith reliance on SCA and orders should bar suppression.
- The district court denies suppression, applying the good-faith exception to exclude suppression of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the SCA permit prospective cell-site data and permit suppression relief? | Jones contends SCA does not authorize such data and lacks suppression remedy. | Government argues SCA authorizes data and remedy is not suppression under SCA. | SCA does not provide a suppression remedy for non-constitutional violations. |
| Whether the government’s acquisition of cell-site data violated the Fourth Amendment and whether the good-faith exception applies. | Jones asserts a Fourth Amendment violation due to the aggregate privacy invasion. | Government relies on good faith, arguing reasonable reliance on SCA and magistrate orders; the data did not require suppression. | Good-faith exception applies; suppression denied. |
Key Cases Cited
- United States v. Jones, 565 U.S. 400 (Supreme Court 2012) (GPS tracking constitutes a Fourth Amendment search (majority).)
- United States v. Maynard, 615 F.3d 544 (D.C. Cir. 2010) (mosaic theory of privacy in long-term tracking (contextual background).)
- Kyllo v. United States, 533 U.S. 27 (Supreme Court 2001) (establishes the reasonable expectation of privacy framework.)
- United States v. Leon, 468 U.S. 897 (Supreme Court 1984) (good-faith exception to exclusionary rule applied to magistrate decisions.)
- Miller v. United States, 425 U.S. 435 (Supreme Court 1976) (third-party doctrine foundational to privacy in voluntary disclosures.)
- Smith v. Maryland, 442 U.S. 735 (Supreme Court 1979) (third-party doctrine; no reasonable expectation of privacy in numbers dialed.)
- United States v. Krull, 480 U.S. 340 (Supreme Court 1987) (unconstitutional reliance on later-ruled law does not automatically trigger suppression.)