U.S. v. STEPHENS, NO. 12-4625
Decided: August 19, 2014
The Fourth Circuit declined application of the exclusionary rule to suppress evidence police officers gathered against Stephens, and affirmed his conviction for illegal possession of a firearm.
In 2011, police officers attached a GPS device to Stephens’s car because of a tip that informed them Stephens, a convicted felon, would be carrying a weapon. The officers used the GPS device to track Stephens to a nightclub and, after his behavior provided the officers with reasonable suspicion, they performed a patdown on Stephens that revealed an empty holster. The officers then used a dog to inspect the outside of Stephens’s car, which led to a search of the car, where they found a firearm. While Stephens’s case was pending, the U.S. Supreme Court decided United States v. Jones, in which it held that “installation of a GPS device on a target’s vehicle . . . constitutes a ‘search’” under the Fourth Amendment. Consequently, although it had previously been standard practice for police to attach GPS devices to a suspect’s vehicle, after Jones that practice had uncertain constitutional validity.
In affirming Stephens’s conviction, the Court reasoned that it would be contrary to the purpose of the exclusionary rule—“deter[ring] future Fourth Amendment violations”—to suppress the evidence gathered against Stephens, even if the search was unconstitutional after Jones. Here, the officers acted in good-faith reliance on what appeared to be a settled legal precedent, and well-established practices. Therefore, admitting the evidence against Stephens was unlikely to lead to future Fourth Amendment violations.
Further, the Court applied the good-faith inquiry here because the officers had acted reasonably by relying on the widely understood legal principal from the U.S. Supreme Court decision in United States v. Knotts. Many courts understood Knotts to support the proposition that use of a beeper to track a vehicle on public roads, and that this action did not constitute a search. Although Jones proved that reading of Knotts was flawed, the Court reasoned that the good-faith inquiry depends on the totality of the circumstances. Here, the circumstances supported introducing the evidence against Stephens, and so the Court affirmed Stephens’s conviction.
James Bull Sterling