Summary
The Supreme Court of Ohio held that the good-faith exception to the exclusionary rule applied to evidence obtained through warrantless placement and monitoring of a GPS tracking device on the defendant's vehicle. Although United States v. Jones later established that attaching such a device constitutes a Fourth Amendment search, officers reasonably relied on then-binding precedent, including United States v. Knotts and United States v. Karo, when conducting the search in 2008. The court affirmed the judgment upholding admission of the evidence.
Topics
Practice areas
Questions Presented
- Whether warrantless placement of a GPS tracking device on Johnson's vehicle violated the Fourth Amendment.
- Whether the good-faith exception to the exclusionary rule applies when police relied on binding appellate precedent that was later superseded by United States v. Jones.
- Whether the GPS-derived evidence should be suppressed despite the Fourth Amendment violation.
Holdings
- Attaching a GPS tracking device to a suspect's vehicle is a search within the meaning of the Fourth Amendment.
- The good-faith exception to the exclusionary rule applies when officers conduct a search in objectively reasonable reliance on binding appellate precedent that later proves incorrect or is superseded.
Key quotations
“searches conducted in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule.” (¶ 42)
“Prior to the Supreme Court’s decision in Jones, its opinions in Knotts and Karo provided binding appellate precedent in this state to support the objectively reasonable conclusion that placing a GPS tracking device on a suspect’s vehicle did not implicate any protections of the Fourth Amendment.” (¶ 49)
“Suppression of the evidence obtained as a result of the GPS device would have no appreciable effect in deterring violations of the Fourth Amendment, and therefore the good-faith exception to the exclusionary rule applies in these circumstances.” (¶ 50)
Factual background
In October 2008, Detective Mike Hackney received information that Johnson was transporting cocaine in a white van and attached a battery-powered GPS tracking device to the van's undercarriage while it was parked on a public street, without obtaining a warrant. Officers used the GPS information to locate and follow Johnson and a companion traveling from Illinois toward Ohio. After traffic stops, officers found seven kilograms of cocaine in a concealed compartment in the companion's vehicle, opened with a key from Johnson's key ring. The GPS evidence supported Johnson's prosecution for cocaine trafficking and possession.
Procedural history
A Butler County grand jury indicted Johnson for cocaine trafficking, cocaine possession, and having a weapon while under a disability. The trial court denied his motion to suppress, and Johnson entered no-contest pleas to the drug charges while being acquitted of the weapons charge; his convictions were merged and he received a 15-year aggregate sentence. The court of appeals initially held that GPS placement was not a search, but the Supreme Court vacated and remanded in light of Jones. After remand, the trial court found the GPS placement unconstitutional but admitted the evidence under the good-faith exception, and the court of appeals affirmed. The Supreme Court affirmed.