United States v. Baez, No. 13-1025 (1st Cir. 2014)Annotate this Case
Defendant pled guilty to four counts of arson. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) obtained by monitoring his automobile using a global positioning system (GPS) device. The ATF began the GPS tracking, without a warrant, in August 2009 and continued for nearly one year. After Defendant filed his notice of appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that the warrantless installation of a GSP device on a defendant’s car and the use of that device to monitor the defendant’s movements for eleven days fell within the good-faith exception to the exclusionary rule because the monitoring had occurred before the U.S. Supreme Court decided United States v. Jones, which held that the installation and use of a GPS tracker on an automobile constitutes a Fourth Amendment search. In the instant case, the First Circuit affirmed the denial of Defendant’s suppression motion, holding that this case fell within the rule laid out in Sparks, although the pre-Jones warrantless GPS tracking was of a significantly longer duration than that in Sparks.