United States v. Castetter, No. 17-1327 (7th Cir. 2017)Annotate this Case
With a warrant, police installed and monitored a GPS locator on Holst's car, while investigating Holst’s participation in methamphetamine sales. Police tracked Holst’s car as it stopped at a particular place for more than an hour. An informant told them that Holst had traveled to buy methamphetamine. Police stopped Holst’s car as he was driving home and found that drug. Other officers obtained a warrant to search the house in whose driveway Holst’s car had stopped. The search of Castetter’s house turned up methamphetamine, other drugs, and approximately $62,000 in cash. Prosecuted under 21 U.S.C. 841(a)(1), Castetter moved to suppress the evidence, arguing that information derived from the first warrant should be ignored because Holst lives in Michigan, where the first warrant issued, while Castetter lives in Indiana. The Seventh Circuit affirmed denial of the motion. The Fourth Amendment does not concern state borders. States may decide not to authorize their police to acquire information extraterritorially or may elect to ignore information from other states’ officers, but Indiana did not do so. Tracking a car by GPS does not offend any state’s sovereign rights. While the first warrant was not based on information about Castetter, all the police learned by monitoring the GPS was the location of Holst’s car. Castetter lacked a privacy interest in that location. The Constitution is not offended if, by executing a warrant to search one person (Holst), police learn incriminating details about another (Castetter).