United States v. Leon
2012 U.S. Dist. LEXIS 42737
D. Haw.2012Background
- Defendant Miguel Leon is charged with possession with intent to distribute methamphetamine; government concedes Fourth Amendment violation due to GPS attachment but argues exclusionary rule does not apply.
- GPS device was attached to the vehicle without a warrant on March 16, 2009 at Matson Navigation; device tracked movement to a parking garage and ultimately to a storage unit.
- A second search warrant was obtained May 28, 2009; no items seized then, but later marijuana-related items and meth were found in storage.
- Placement of the GPS device was governed by binding Ninth Circuit law at the time (McIver), which held warrantless attachment did not violate the Fourth Amendment when the vehicle was in open view.
- Prolonged monitoring of the GPS device to track movements occurred in 2009; as of 2009 there was no binding circuit precedent approving prolonged GPS tracking, though pre-2009 cases suggested limited privacy expectations in public.
- Post-2009, subsequent rulings (e.g., Pineda-Moreno, 2010) upheld GPS tracking in similar contexts, but Jones (2012) held GPS monitoring constitutes a search; the court applies Davis and relevant precedent as of 2009 to assess deterrence and good-faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the exclusionary rule applies to GPS evidence here | United States argues deterrence is not appreciable; suppression unwarranted. | Leon argues suppression is warranted to deter Fourth Amendment violations. | Exclusionary rule does not apply; suppression denied. |
| Whether placement of the GPS device was lawful under binding precedent as of 2009 | Placement was justified by McIver; no reasonable expectation of privacy in exterior vehicle area. | Leon contends placement violated privacy expectations, regardless of later Jones guidance. | Placement permitted under binding precedent; no suppression for this component. |
| Whether prolonged use of the GPS device constitutes an unlawful search in 2009 | Use violated Fourth Amendment in light of evolving doctrine (Davis framework). | Government relied on objectively reasonable good-faith belief and Knotts rationale. | Objectively reasonable good-faith belief; deterrence not served; suppression not warranted. |
Key Cases Cited
- United States v. Knotts, 460 U.S. 276 (Supreme Court 1983) (automobile movements have diminished privacy expectations; tracking in public is allowed)
- United States v. McIver, 186 F.3d 1119 (9th Cir. 1999) (warrantless GPS placement allowed when no reasonable privacy in vehicle exterior)
- United States v. Garcia, 474 F.3d 994 (7th Cir. 2007) (early GPS tracking precedent within circuit court)
- United States v. Pineda-Moreno, 591 F.3d 1212 (9th Cir. 2010) (prolonged GPS tracking considered constitutional by some Ninth Circuit judges)
- Davis v. United States, 131 S. Ct. 2419 (Supreme Court 2011) (exclusionary rule deterrence-based; good-faith reliance matters)
- Herring v. United States, 555 U.S. 135 (Supreme Court 2009) (deterrence-based approach to the exclusionary rule; cost-benefit analysis)
- Jones v. United States, 132 S. Ct. 945 (Supreme Court 2012) (GPS monitoring constitutes a search under Fourth Amendment)