United States v. Oladosu, No. 13-1332 (1st Cir. 2014)
Annotate this CaseA law enforcement officer placed a GPS device on Defendant’s vehicle without a warrant and used that device to track Defendant’s movements for forty-seven days. The GPS monitoring ultimately led to Defendant being charged with, and pleading guilty to, possessing and conspiring to possess heroin with the intent to distribute it. After Defendant moved to suppress the evidence obtained as a result of the warrantless GPS monitoring, the 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. The district court denied Defendant’s motion to suppress, determining that the exclusionary rule should not apply in this case because the officers had relied in good faith on pre-Jones legal precedent. Before the parties briefed the case on appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that eleven days of pre-Jones warrantless GPS tracking fell under the good-faith exception to the exclusionary rule. The First Circuit affirmed, holding that, for the reasons articulated in Sparks and United States v. Baez, another case decided today, the exclusionary rule applied to the officers’ warrantless GPS monitoring of Defendant's vehicle.
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