State of South Dakota v. Joseph A. Jones

Summary

The South Dakota Supreme Court considers whether law enforcement’s warrantless, continuous use of a pole camera to surveil activity outside Joseph Jones’s home violated the Fourth Amendment. The court applies the reasonable-expectation-of-privacy test and addresses the significance of targeted, long-term video surveillance. The opinion states that the circuit court’s suppression ruling was reversed in part and affirmed in part.

Holdings

1. The warrantless use of a pole camera specifically installed to chronicle and observe a suspect's activities outside his residence continuously and remotely for approximately two months constituted a search under the Fourth Amendment and required a warrant.
2. The good-faith exception to the exclusionary rule applied because the detective acted reasonably in believing that a warrant was not required before installing the pole camera, and suppression would not deter deliberate or negligent law-enforcement misconduct.
3. The State waived its challenge to the circuit court's determination that the warrant affidavits lacked sufficient probable cause after the pole-camera information was removed because it did not file a notice of review.

Questions Presented

1. Whether warrantless, targeted, continuous pole-camera surveillance of activity outside a residence for approximately two months constitutes a search under the Fourth Amendment.
2. Whether evidence obtained through warrants supported substantially by information from the pole-camera surveillance must be suppressed.
3. Whether the good-faith exception to the exclusionary rule applies when officers reasonably believed that a warrant was not required before installing the pole camera.
4. Whether the State waived its challenge to the circuit court's determination that the warrant affidavits lacked probable cause after removal of the pole-camera information.

Disposition

other