United States v. Sparks
2010 U.S. Dist. LEXIS 120257
| D. Mass. | 2010Background
- Bank robbery in Waltham on Jan 4, 2010; suspects fled in a red SUV with masked robbers, ~$10,676 seized.
- FBI placed a GPS device on Sparks's Chrysler Dec 24, 2009, power from its own battery, initial parking in a private lot.
- GPS data showed vehicle movements including Charlestown and Waltham; FBI reestablished surveillance after a chase.
- Chrysler contained items from search warrant and Sparks's wallet; Michaud apprehended with bank money bands; multiple items link to robbery.
- Motion to suppress GPS evidence based on Fourth Amendment/privacy raised; court denied suppression, applying Knotts/Karo framework and balancing technology vs privacy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GPS installation on exterior in private parking lot violates Fourth Amendment | Sparks claims privacy in parking lot and vehicle exterior | Government argues no reasonable expectation in parking lot or exterior | No reasonable expectation; installation not a search |
| Whether monitoring GPS movements on public streets violates Fourth Amendment | Aggregated movements invade privacy over time | Movements on public streets not protected; aggregation not warrant require | Not a search; monitoring public movements admissible |
| Whether Knotts controls; prolonged GPS surveillance different from Maynard | Maynard requires warrant for prolonged GPS | Knotts permits beeper-like tracking without warrant | Knotts control; prolonged surveillance not treated as search here |
Key Cases Cited
- Katz v. United States, 389 U.S. 347 (U.S. 1967) (two-part Katz objective/subjective expectancy test)
- United States v. Karo, 468 U.S. 705 (U.S. 1984) (tracking device reveals private information; not always required warrant)
- United States v. Knotts, 460 U.S. 276 (U.S. 1983) (no reasonable expectation of privacy in public travel; beeper tracking allowed)
- Pineda-Moreno, 591 F.3d 1212 (9th Cir. 2010) (GPS tracking on vehicle; aggregation considerations discussed)
- Maynard v. D.C. Circuit, 615 F.3d 544 (D.C. Cir. 2010) (prolonged GPS surveillance; warrants issue considerations)