One Year After Landmark Decision, GPS Tracking Law Remains Unclear

Photo courtesy of Smithsonian National Air & Space Museum
Photo courtesy of Smithsonian National Air & Space Museum

by Lauren Gailey, Staff Writer

A year ago last week, the U.S. Supreme Court handed down an opinion addressing an issue that has become increasingly common in today’s technologically advanced society:  is law enforcement’s use of a GPS tracking device to surveil a suspect a “search” protected by the Fourth Amendment?  In United States v. Jones, decided on January 23, 2012, the Court answered that question with a “yes” – seemingly settling the question.  The aftermath of the Jones decision, however, has been anything but settled.

Interestingly, when faced with such advanced technology, Justice Antonin Scalia and the majority adopted an approach that was anything but novel.  Since the Katz decision in the 1960s, the Court had determined whether law enforcement’s actions were a search subject to Fourth Amendment protection by asking whether the person being surveilled had a “reasonable expectation of privacy” in his or her behavior.  In Jones, however, the Court returned to the pre-Katz approach, which was based on the concept of trespass.  The Court held that the agents’ placement of the GPS was a Fourth Amendment search because law enforcement agents did not have a warrant when they trespassed on the suspect’s vehicle by attaching the GPS device, which they then used to surveil him.

“Ironically,” Justice Samuel Alito quipped in his scathing concurrence, “the Court has chosen to decide this case based on 18th-century tort law.”  Justice Alito predicted that, because Jones’ holding was rooted in property concepts, it would “present particularly vexing problems” when applied to electronic surveillance.

In the year since Jones was decided, the federal district and circuit courts have been confronted with many of these electronic surveillance decisions – and, based on those cases, Justice Alito’s prediction appears to have been correct.  The federal courts’ handling of Jones has varied widely, perhaps due to the many important questions left open by the Court.  For example, whether the Jones framework applies at all outside the GPS-tracking arena is unclear, and most courts that have taken up that question – including the first Circuit to do so, the Sixth, in a cell phone surveillance case – have sidestepped Jones and applied the old Katz test instead.

Interestingly, although Justice Scalia said otherwise in the majority opinion, the decision has seemingly called the continued validity of the Katz test into question entirely in this context.  Where the federal courts continue to use it, many apply Katz in lieu of Jones where the facts permit.  Others attempt to apply both tests simultaneously, and still others use Katz as a “fall-back” where the surveillance at issue is found not to be a Fourth Amendment search under Jones.

The Court also did not answer the question of whether any exceptions to the Fourth Amendment’s warrant requirement apply to GPS “searches.”  Many of the lower courts have, in absence of any direction, permitted exceptions such as agents’ good-faith reliance on binding and, in some cases, non-binding appellate precedent.  Clearly, the federal courts’ approaches to the Jones decision have been heavily fragmented, and the state courts that have been faced with electronic surveillance cases have experienced similar problems.

The unfortunate coincidence is that, given the game-changing significance of the Jones decision for law enforcement, legal uniformity and certainty would seem to be all the more critical.  Former FBI counterterrorism official Ray Mey explained to USA Today that, due to the limitations of vehicle surveillance, the attachment of GPS devices to suspects’ vehicles “is one of the only ways to pinpoint the locations of suspects.”  In the immediate aftermath of Jones, the FBI seemed to adopt a “better-safe-than-sorry” approach to GPS tracking.  In fact, FBI General Counsel Andrew Weissman told a Wall Street Journal blogger in February of last year that the agency had shut off 3,000 of its devices that were in use at the time the Jones decision came down.

Now that the law enforcement agencies have had time to adjust to the new legal landscape, however, the extent of the limitations on their use of technologies like GPS tracking has become much less clear.  According to the American Civil Liberties Union’s website, the Department of Justice has prepared internal memoranda about the applicability of Jones to the investigative process, but released heavily redacted versions in response to the ACLU’s disclosure request.  Last month, the DOJ refused to release the unredacted memoranda, and the ACLU has said that it will ask the court to order the DOJ to do so under the Freedom of Information Act.

Despite the legal uncertainty that has followed Jones’ interpretation of the Fourth Amendment, what is certain is that warrantless GPS tracking by law enforcement has earned its share of detractors on the federal bench.  Dissenting in a pre-Jones case that ruled a similar use of warrantless GPS tracking constitutional, Judge Diane Wood of the Seventh Circuit stated that such searches “make the system that George Orwell depicted in his famous novel, 1984, seem clumsy and easily avoidable by comparison.”

[Read the full text of the Jones decision here.]

 

Lauren Gailey is a second-year student who has studied at Georgetown University and the University of Pittsburgh, where she earned bachelor’s degrees in Marketing and Communication and Rhetoric.  Lauren has interned in the Office of the United States Attorney for the Western District of Pennsylvania.  Before law school, she worked as a producer of a cable television news-talk show.

 

 

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  700. One of the best pastimes in the world is camping outdoors. Camping outdoors permits you to encounter all that the excellent in the open air offers and permits you to take pleasure in the advantage of mother nature. Are you currently considering moving camping out? Then, then try some of the camping outdoors recommendations in the write-up beneath. If you are going backcountry camping outdoors, you must most likely possess a snake mouthful set within your products. The most effective snake chew kits are the types which use suction. Some kits have scalpels and the flow of blood constrictors with them. Scalpels can actually cut the poison to the blood stream faster, and constrictors can be lethal or even used effectively. Prior to deciding to set off on your extended-anticipated camping outdoors vacation, make sure the location where you want to camp doesn’t require a camping outdoors allow. If you happen to camp inside a spot that does need one particular so you didn’t purchase one, then you could be experiencing a serious hefty ticket or great from a neighborhood forest ranger. With camping out, arrives the campfire. Ensure your campfire is in a wide open room and considerably enough far from brush or trees and shrubs therefore you don’t manage the chance of a stray spark capturing them on fireplace. Surrounds the blaze with gemstones to help keep it contained. Above all, by no means leave any campfire unattended. If you have to abandon for any reason, make sure the campfire is extinguished completely. Always pack and carry a success set. Your emergency system must consist of a success blade, drinking water-purifying pills, water resistant fits, first aid kit, along with a flare firearm. You require this should you grow to be misplaced or stranded those items within your package could keep your life. Make sure to bring it wherever you go when you’re from your campsite. Now that you determine what to bring, you could start preparing your own personal camping out getaway. This information has supplied you with info on the primary things necessary for any camper preparing to enterprise in the outdoors, so never forget them. They will come in helpful making your camping outdoors encounter a satisfying 1.

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  707. Anyone who has ever been camping out understands how pleasurable it could be. Sleeping and awakening to mother nature is one of the most soothing things imaginable. If you haven’t the least idea of steps to start camping out, read the subsequent post. Before you decide to go out on your own very long-anticipated outdoor camping journey, make sure the location where you plan to camp doesn’t call for a camping outdoors allow. Should you camp within a position that does need one particular so you didn’t obtain one, then you might be facing a significant significant admission or good from the community forest ranger. In case you are going with young children, take into account staying at a campground that is certainly specifically selected for people. Travelers within these regions know what to anticipate and may not have a concern if you have a cranky child or even your young children desire to play, scream and enjoy. You will probably be calm as a result and also have a greater time. Before you bring your puppy together for the camping getaway, get him utilized to the idea with some process run from the backyard. Pitch the tent in an currently common location, and allow him to sleep at night or engage in inside for quite a while. Taking a pet dog can really add to the exciting of camping out, as long as the animal is adequately ready for the event. Take a look at just what the conditions will probably be like before leaving to your spot. You can check out http://www.conditions.com to determine the climate just about anyplace. Make sure you look at the 10 working day forecast together with prolonged conditions designs. These details may help you far better get prepared for extreme climatic conditions. With the assistance presented on this page, there is the important information to organize an excellent camping out getaway. Utilize the information you learned to turn into a master camper. No matter how considerably you travel, you will have a great outdoor camping expertise.

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  709. Camping is one thing which is fun for the entire household. If you are new to camping, or are a experienced seasoned, there are always facts you must think about before venturing out in your after that camping outdoors trip. The next article can help prepare you for the next trip allowing you to have an effective and harmless time. If you are camping at the open public camping site, ensure you pack shower room shoes for anyone in your get together. Not only will they shield your feet through the microorganisms around the bath surface, but are perfect for those nighttime operates for the bushes when you should employ the restroom. They can be outdated flick flops, Crocs, or perhaps fall-ons. Plan accordingly with regards to foods. It really is a inconvenience to make room inside your car for all the food you will need. Nonetheless, correct sustenance is very important when you are in the forest. Also, products which are pretty economical in your neighborhood shop often have a increased price close to camping out sites. Delivering adequate meals ensures that you can expect to spend less whilst keeping everybody inside your family members inside a excellent mood. Check out grocery stores near your campsite. Make sure you realize how to reach them. Particularly, if your trip is spanning greater than 3 or 4 times, the meal you provide along probably isn’t gonna final the duration of your vacation. Not merely, that, but your family will get tired with consuming exactly the same issues every single day. Variety is extremely important. Understand that your family and belongings will get filthy. Although infant baby wipes can be used to help for several level of hygiene, expect that men and women will receive filthy. Be ready for it and agree to it. Enjoy your time and energy within the forests by letting your self relax and acquire dirty. You will get thoroughly clean when you get home. A fantastic trip awaits you. Using the suitable info and planning, you may make it happen. These tips will make your planning easier and more successful. It a very good idea to continually try to find any details that will boost your practical experience.

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  712. Many people are attracted to outside experience like steel filings are attracted to a magnet. The easiest way to increase any camping excursion is always to left arm yourself with understanding of the most useful guidelines. Are you prepared for your finest journey actually? To increase your resting practical experience while outdoor camping, deliver a pad coupled you could place under your sleeping bag. This cushion provides a shield among you and also the tough floor where twigs and shrub knots may cause peculiar getting to sleep conditions. If your cushion isn’t helpful, take several extra covers that one could collapse more than on them selves to make some pillow. Especially, if you have children, you should look at what to do for those who have bad weather conditions one day. Collect with each other several products to have available just in case you will need to remain in your tent. Deliver a board activity, engage in doh and craft supplies. Don’t enable your family members participants touch these products right up until it rains to make sure they don’t get rid of their attraction. Always keep the needs of your household under consideration prior to buying a spot. By way of example, in case you have a child or child, it could be best to stick in close proximity to residence in case things don’t go as arranged. For those who have young people, even so, you may get pleasure from traveling to a new express. Select what is perfect for you! Generally load up and possess a emergency set. Your success system should have a success blade, water-cleansing tablet pcs, water resistant complements, first aid kit, plus a flare weapon. You want this when you come to be shed or stuck the products inside your set might save your valuable daily life. Make sure to bring it wherever you go when you’re from your campsite. Since you now know what to do, begin planning your outdoor camping excursion. Acquire what you’ve learned here to center, and you’ll be a professional camper in no time. Whether you are searching for a saturday and sunday retreat or even an considerable outdoor camping trip, you will certainly be sure to have a good time.

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