United States v. Jones case brief

United States v. Jones case brief summary
132 S. Ct. 945
SYNOPSIS: 

-Defendant was charged with drug conspiracy under 21 U.S.C.S. §§ 841 and 846. A district court denied in part defendant's motion to suppress evidence obtained through a global-positioning-system (GPS) device under the Fourth Amendment. 

-A jury returned a guilty verdict. 

-The United States Court of Appeals for the District of Columbia Circuit reversed the conviction and denied the Government's petition for rehearing en banc. Certiorari was granted.

FACTS: 

-Defendant came under suspicion of trafficking in narcotics. 

-Agents installed a GPS tracking device on the undercarriage of a vehicle registered to defendant's wife while it was parked in a public parking lot. 

-Over the next 28 days, the Government used the device to track the vehicle's movements. 

-The Government conceded noncompliance with a warrant that had been obtained. 

-The appellate court found that admission of the evidence obtained by warrantless use of the GPS device violated the Fourth Amendment.

HOLDING:

-The U.S. Supreme Court determined that the Government's installation of the GPS device on defendant's vehicle, and its use of that device to monitor the vehicle's movements, constituted a "search."

ANALYSIS:

-Under the common-law trespassory test, the Government physically occupied private property for the purpose of obtaining information. 

-Such a physical intrusion would have been considered a "search" within the meaning of the Fourth Amendment when it was adopted. 

-Defendant possessed the vehicle at the time the Government trespassorily inserted the information-gathering device. 

-The Government forfeited its alternative argument that officers had reasonable suspicion and probable cause.

OUTCOME: The Court affirmed the appellate court's judgment. 9-0 Decision; 2 Concurrences.

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