USA v. Davis, No. 23-10184 (11th Cir. 2024)
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The case involves Johnnie Davis, who was convicted of committing multiple carjackings in Montgomery, Alabama. Before his trial, Davis sought to suppress evidence obtained through a geofence warrant that tracked his girlfriend’s phone and his inculpatory statements made after his arrest. He also argued that the government failed to prove his intent to cause death or serious harm during the carjackings. The district court denied his motions.
The United States District Court for the Middle District of Alabama initially reviewed the case. Davis moved to suppress the evidence obtained from the geofence warrant and his post-arrest statements, arguing that the warrant was invalid and that he should have been presented to a federal magistrate judge before being interviewed. The district court found that Davis lacked Fourth Amendment standing to challenge the geofence warrant and that the federal presentment requirements did not apply as he was in state custody. The court also found sufficient evidence of Davis’s intent to cause death or serious harm and denied his motion for judgment of acquittal.
The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Davis lacked Fourth Amendment standing to challenge the geofence warrant because the search did not disclose any information about his own electronic device and only reflected his limited movements in public areas. The court also agreed with the district court that the federal presentment requirements did not apply since Davis was in state custody and there was no improper collusion between federal and state law enforcement. Finally, the court found that Davis’s use of a gun during the carjackings sufficiently established his intent to cause death or serious harm. The Eleventh Circuit affirmed the district court’s decisions.
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