United States v. Jones Case Brief: Supreme Court Ruling on GPS Tracking and Fourth Amendment Protections

Case Brief: United States v. Jones

Court: Supreme Court of the United States
Citation: 565 U.S. 400 (2012)
Argued: November 8, 2011
Decided: January 23, 2012

---

Facts:

In United States v. Jones, law enforcement agents suspected Antoine Jones, a drug dealer, of engaging in illegal activity. Without obtaining a warrant, the government attached a GPS tracking device to Jones's vehicle. The device tracked his movements for 28 days, providing significant data about his whereabouts, which was later used to obtain evidence for his conviction on drug-related charges. Jones was arrested and convicted, and he argued that the use of the GPS tracking device without a warrant violated his Fourth Amendment right against unreasonable searches and seizures.

Jones moved to suppress the evidence obtained from the GPS tracker, claiming that its use constituted a warrantless search. The trial court denied the motion, and Jones was convicted. On appeal, the D.C. Circuit Court of Appeals reversed, concluding that the GPS tracking without a warrant was unconstitutional. The government appealed to the Supreme Court.

Issues:

1. Whether the installation of a GPS tracking device on a suspect's vehicle constitutes a search under the Fourth Amendment.
2. Whether the prolonged use of a GPS device to track a vehicle's movements for 28 days without a warrant violates the Fourth Amendment.

Holding:

The Supreme Court ruled unanimously that the installation of a GPS tracking device on Jones's vehicle, and its prolonged use to track his movements, violated the Fourth Amendment. The Court held that the physical attachment of the GPS device to the vehicle constituted a search, and that the prolonged surveillance of Jones's movements violated his reasonable expectation of privacy.

Legal Reasoning:

• Fourth Amendment and Physical Intrusion: In an opinion written by Justice Scalia, the Court emphasized the "trespass" theory of the Fourth Amendment. The Court found that the physical attachment of the GPS device to Jones's vehicle was a "physical intrusion" onto his private property, which is considered a search under the Fourth Amendment. The Court held that the warrantless attachment of the GPS device constituted a search because it physically interfered with Jones's property.

• Expectations of Privacy and Prolonged Surveillance: The Court also considered the long-term surveillance aspect of the case. It noted that prolonged surveillance of a person’s movements, particularly over an extended period of time, could reveal private details about an individual’s life. The Court highlighted that 28 days of tracking could expose a person's routine, travels, and associations in a way that violates the expectation of privacy that the Fourth Amendment seeks to protect.

• Narrow vs. Broad Approach: The Court’s decision focused on the physical intrusion aspect of the case, without ruling definitively on whether the surveillance violated the Fourth Amendment due to the nature of the data collected. This left the door open for further consideration of whether long-term GPS tracking without a warrant might violate privacy expectations under a different theory, such as the reasonable expectation of privacy test from Katz v. United States, 389 U.S. 347 (1967).

Concurring Opinions:

• Justice Alito concurred in the judgment but argued that the decision should be based on the reasonable expectation of privacy test, rather than focusing solely on the physical intrusion. Alito suggested that prolonged GPS surveillance is a violation of privacy because it allows law enforcement to track an individual’s movements over an extended period, revealing intimate details of one’s life.

• Justice Sotomayor also wrote a concurring opinion, agreeing with the judgment but emphasizing the potential privacy concerns surrounding modern surveillance technology. She suggested that the use of such technology could have far-reaching implications for privacy and should be closely scrutinized.

Dissenting Opinion:

• Justice Kennedy, joined by Justices Ginsburg and Kagan, dissented, arguing that the Court should have adopted a more modern, technology-driven approach to the case. He noted that the warrantless GPS tracking did not necessarily amount to a violation of the Fourth Amendment, especially in light of the ubiquity of modern technology and the need for law enforcement to adapt to new methods of investigation.

Conclusion:

The U.S. Supreme Court ruled that the warrantless use of a GPS tracking device to monitor the movements of a suspect over a 28-day period violated the Fourth Amendment. The Court reasoned that the physical attachment of the device to Jones's vehicle was a search, and the prolonged surveillance of his movements invaded his reasonable expectation of privacy.

---

List of Cases Cited:

1. Katz v. United States, 389 U.S. 347 (1967) - Established the reasonable expectation of privacy test for Fourth Amendment protections.
2. United States v. Jones, 565 U.S. 400 (2012) - The Supreme Court ruling on the use of GPS tracking devices and Fourth Amendment rights.
3. United States v. Knotts, 460 U.S. 276 (1983) - A prior case involving the use of a beeper to track a suspect, where the Court ruled that tracking a car with the beeper was not a search.

---

Similar Cases:

1. United States v. Knotts, 460 U.S. 276 (1983) - Addressed the use of beepers to track vehicles and concluded that short-term surveillance did not violate the Fourth Amendment.
2. Kyllo v. United States, 533 U.S. 27 (2001) - Held that the use of thermal imaging devices to detect heat from a home was a search under the Fourth Amendment, even without physical intrusion.
3. Riley v. California, 573 U.S. 373 (2014) - Held that searching the contents of a cell phone without a warrant violated the Fourth Amendment, drawing on similar principles of privacy in the digital age.