The 1st U.S. Circuit Court of Appeals, in United States v. Sparks, et al., contemplated the recent SCOTUS ruling in US v. Jones before ruling that evidence obtained as a result of a warrantless placement of a global positioning system device on a car could be admitted at trial.
The defendants argued that, under the U.S. Supreme Court’s 2012 decision in United States v. Jones, the federal agents’ use of the GPS tracker was a Fourth Amendment “search” that required a warrant.
The 1st Circuit, however, found the evidence admissible pursuant to the good-faith exception to the exclusionary rule articulated by the Supreme Court in the 2011 case of Davis v. United States.
“Davis’s good-faith exception is not a license for law enforcement to forge ahead with new investigative methods in the face of uncertainty as to their constitutionality,” Judge Norman H. Stahl wrote for the unanimous court. “The good-faith exception is, however, properly applied in cases like this one (or Davis itself), where new developments in the law have upended the settled rules on which the police relied.”