United States v. Matthew Martin
712 F.3d 1080
7th Cir.2013Background
- Martin, a convicted felon, pleaded guilty to possessing a firearm under 18 U.S.C. § 922(g) with a conditional plea preserving Fourth Amendment challenges to evidence found in his car.
- We previously affirmed the district court’s denial of suppression; Jones established GPS tracking as a Fourth Amendment search, prompting restricted remand.
- On remand, the district court held suppression was not warranted under Davis’s good-faith exception based on reliance on then-existing precedent.
- We rejected expanding Davis to cover unsettled law around GPS searches and noted there was no binding Eighth Circuit precedent at the time of the GPS installation.
- The facts showed the GPS evidence was attenuated from the unlawful installation and largely aided pursuit of arrest, not the initial seizure itself; we denied rehearing en banc.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Davis allows admission of evidence despite unsettled GPS law | Martin argues Davis cannot justify suppression when law governing the search was unsettled | United States argues Davis permits good-faith reliance on precedent | We reject extending Davis; suppression not automatically required |
| Whether GPS evidence was attenuated from the unlawful installation | Martin contends GPS data tainted the evidence | United States contends attenuation cleanses the nexus to the illegal act | Evidence attenuated; suppression not warranted |
Key Cases Cited
- United States v. Jones, 132 S. Ct. 945 (2012) (GPS tracking constitutes a search under the Fourth Amendment)
- Davis v. United States, 131 S. Ct. 2419 (2011) (good-faith exception limited to reliance on binding appellate precedent)
- United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to the exclusionary rule)