United States v. Jones

Supreme Court of the United States · 2012 · Criminal Procedure
565 U.S. 400 (2012)
Updated
Criminal ProcedureFourth AmendmentSearchesGPS trackingsearchGPS devicevehicleeffects

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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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Detectives in Phoenix suspect Omar Ruiz of burglary. While his motorcycle is parked on a public street, an officer crouches down, magnetically attaches a small locator to the frame, and uses it for ten days to map the motorcycle’s route around the city.

Did the officers conduct a Fourth Amendment search?

Explanation. The majority rule is that the Government conducts a search when it physically intrudes on a constitutionally protected area—such as an effect—for the purpose of obtaining information. A motorcycle is an effect. The attachment plus use of the locator to gather route information is enough to constitute a search, even if the movements occurred in public and even if Katz might not independently be violated.