United States v. Sparks, No. 11-1134 (1st Cir. 2013)
Annotate this CaseIn 2009, federal agents, acting without a warrant, placed a global positioning system (GPS) tracker on a car used by Craig Sparks. The agents located the car at the scene of a bank robbery and chased down the car on the highway after it fled, all by using the tracker. A subsequent search of the car revealed evidence tying Sparks and Michaud (Appellants) to the bank robbery. After Appellants were indicted for bank robbery, they moved to suppress the evidence obtained as a result of the placement of the GPS tracker on the car. The district court denied the motion, concluding that the case was governed by United States v. Knotts, which held that using a radio-based tracking device to tail a suspect's car was not a Fourth Amendment search. Appellants appealed, arguing that the U.S. Supreme Court's recent decision in United States v. Jones required reversal of the district court's decision. The First Circuit Court of Appeals affirmed without reaching the question, holding that the agents' conduct fit within the good-faith exception to the exclusionary rule, and therefore, the district court did not err in denying Appellants' motion to suppress.
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