United States v. Sparks
711 F.3d 58
| 1st Cir. | 2013Background
- FBI agents without a warrant attach a GPS tracker to Sparks's car in December 2009.
- Tracker enables real-time location; tracker battery operates independently of the car; battery replaced December 29.
- On January 4, 2010, agents locate the car and subsequently observe a bank robbery in Massachusetts via the tracker.
- Following the robbery, suspects flee; the Chrysler is pursued and a search yields weapons, clothing, gloves, and cash.
- Michaud is apprehended later the same day; Sparks is later arrested in Maine; both are indicted.
- District court denied suppression; Jones decision issued after, prompting appellate reconsideration under good-faith grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does GPS tracking constitute a Fourth Amendment search requiring a warrant after Jones? | Sparks contends GPS tracking is a search needing a warrant. | Government argues control via Jones; not decide warrant necessity here due to good-faith. | Court does not resolve warrant question; applies good-faith exception. |
| May evidence obtained from warrantless GPS tracking be excluded under the good-faith exception? | Sparks argues exclusion is mandatory if tracking violated the Fourth Amendment. | Government argues Davis good-faith applies because precedent authorized conduct. | Suppression inappropriate under Davis good-faith exception. |
| Is the good-faith exception limited to reliance on binding circuit precedent as of Jones? | Sparks argues reliance on pre-Jones precedent is insufficient to invoke good faith. | Government contends binding circuit precedent authorized the conduct. | Binding circuit precedent authorized the conduct; good-faith applies. |
Key Cases Cited
- United States v. Jones, 132 S. Ct. 945 (2012) (GPS monitoring constitutes a search under Fourth Amendment)
- Knotts, 460 U.S. 276 (1983) (beeper tracking on public roads not a search)
- Moore, 562 F.2d 106 (1st Cir. 1977) (trespass in attaching beeper minimal; beeper surveillance allowed with probable cause)
- Davis, 131 S. Ct. 2419 (2011) (good-faith exception for reliance on binding precedent)
- Karo, 468 U.S. 705 (1984) (beepers and privacy in movements; beeper in equipment case)