United States v. Jones
Facts
Officers obtained a warrant authorizing installation of an electronic tracking device on a Jeep used exclusively by Jones, but they installed the GPS device on the Jeep's undercarriage on the 11th day and in Maryland rather than in the District of Columbia. They then used the device to monitor the vehicle's movements on public streets for 28 days, generating more than 2,000 pages of location data. At Jones's later trial, the Government introduced the GPS-derived data, which connected him to a stash house, and he was convicted. The Government conceded noncompliance with the warrant in this litigation and argued only that no warrant was required.
Issue
Whether the Government's attachment of a GPS tracking device to a person's vehicle, and its use of that device to monitor the vehicle's movements on public streets, constitutes a search within the meaning of the Fourth Amendment.
Rule
The Government conducts a Fourth Amendment search when it physically intrudes on a constitutionally protected area such as a person, house, paper, or effect for the purpose of obtaining information. The Katz reasonable-expectation-of-privacy test adds to, rather than substitutes for, this common-law trespassory understanding.
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Did the officers conduct a Fourth Amendment search?