United States v. Karo case brief

United States v. Karo case brief summary
468 U.S. 705 (1984)

CASE SYNOPSIS

Petitioner government sought certiorari review of an order of the United States Court of Appeals for the Tenth Circuit affirming the district court's order suppressing evidence obtained through use of a beeper installed without a warrant, in respondents' trial on federal drug charges.

CASE FACTS
Government agents, acting without a warrant, placed a beeper in a can of ether. Monitoring of the beeper led to a search of a residence, which yielded illegal drugs. Prior to respondents' trial on drug charges, the district court suppressed the evidence, finding that the warrantless beeper invalidated the subsequent search.

DISCUSSION

• The circuit court affirmed the district court's order, but the Court reversed the circuit court's decision. 
• The Court ruled that a warrant was not required for the placement of the beeper in the can because the can was owned by the government, and it was switched with a can owned by a government informant. 
• Moreover, the Court ruled that the transfer of the can from the informant to respondents was not a search or seizure because the transfer did not invade respondents' privacy. 
• The warrantless monitoring of the beeper was unconstitutional because respondents had an expectation of privacy in a private residence. 
• The Court ruled, however, that the seized evidence was not subject to suppression because the affidavit information, absent the evidence obtained through the beeper, was sufficient to support probable cause to issue the warrant.

CONCLUSION

The Court reversed the circuit court's order affirming the district court's order suppressing evidence obtained through use of a beeper because evidence obtained, independent of the invalid beeper monitoring, supported the issuance of the warrant to search the residence.

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