United States v. Watkins, No. 18-14336 (11th Cir. 2020)
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The Eleventh Circuit reversed the district court's grant of defendant's motion to suppress evidence on Fourth Amendment grounds. Law enforcement agents had placed a GPS tracking device in two packages after finding cocaine hidden in them. The agents put both packages into the mail stream and attempted to track the packages.
Even assuming the warrantless monitoring of the GPS tracking device signal from the package once it entered the house was a violation of the Fourth Amendment, the court held that there is a reasonable probability that the evidence would have been discovered anyway. The court explained that the evidence incriminating defendant would have been discovered through ongoing investigation and the pursuit of leads that were already in the possession of the agents at the time the device started functioning and they monitored it. In this case, defendant was the lead suspect; the agents had already looked up information about her and had obtained her address; they were discussing doing a knock and talk at her house, which would not have required a search warrant; at the moment the tracking device reactivated, they were actively discussing doing it; and it is not as if the knock and talk is a novel or unfamiliar investigative technique: collectively the agents had done hundreds of them.
The court issued a subsequent related opinion or order on August 20, 2021.
The court issued a subsequent related opinion or order on September 16, 2021.
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