Fourth Amendment Case Brief
United States, Petitioner v. Antoine Jones, US Supreme Court, 20120
Key Facts
The United States (US) was the petitioner against Antoine Jones, appearing at the US Supreme Court. The case was argued on November 8, 2011, and decided on January 23, 2012, with Justice Scalia delivering the opinion of the Court. Antoine Jones was the owner and operator of a nightclub in the District of Columbia (DC) when he came under suspicion of trafficking in narcotics. Hence, a joint FBI and Metropolitan Police Department task force targeted him for an investigation, which included surveilling the nightclub and installing a camera focusing on the club’s front door. A pen register and wiretap covering Jones’ cellular phone was also used in the investigation. The information gathered using the techniques was used by the Government in 2005 to apply to the US District Court for DC for a warrant authorizing an electronic tracking device on a vehicle registered to Jone’s wife. The authorization was granted within 10 days and agents installed a GPS tracker on the Jeep’s undercarriage in Maryland.
Subsequently, when the Government used the data to obtain indictment charges against Jones and alleged co-conspirators, he filed a motion to suppress evidence acquired through the GPS device. Although the District Court granted the motion in part, Jones’ trial in 2006 resulted in a hung jury on the conspiracy count but later sentenced him to life imprisonment in 2007. Upon appeal, the US Court of Appeals for the DC Circuit reversed the evidence was obtained by warrantless GPS device use, thus violated the Fourth Amendment. Since the DC Circuit denied the Government’s petition to rehear the case, with four judges dissenting, the US Supreme Court granted a review or “certiorari” of the matter. Therefore, the procedural history of US v. Jones is that the case came from the Appeals Court to the Supreme Court as a judicial review.
Issue
The issue the Court was asked to address was whether the attachment of the GPS tracking device to an individual’s vehicle for use in monitoring movement constituted a search and seizure under the Fourth Amendment. Newton observes that the application of the Fourth Amendment is one of the leading issues the Supreme Court has decided within the last decade (2). Consideration of matters under the Amendment is crucial in checking the government authority because they are ubiquitous in the everyday lives of Americans. The issue affects the authorities’ ability to search a person and property, listen to conversations, read private messages, and detain individuals (Newton 3). The relevant part of the Fourth Amendment to the US v. Jones concerned the right of the people to be secure against unreasonable searches and seizures, specific to their persons, houses, papers, and effects, which shall not be violated. Hence, the Court was supposed to make a ruling since the Government had physically occupied private property, the Jeep, to obtain information.
Rule
The Court, in the US v. Jones, relied on the trespass theory as the rule to determine whether the policy invaded private property while attaching the GPS device. For example, Justice Scalia noted that the Fourth Amendment jurisprudence was tied to common-law trespass. Hence, the Government’s installation of a GPS device constituted a “search” (US v. Jones). Notably, the Government physically occupied private property with the intent to obtain information. The act constituted a physical intrusion and applied Entick v. Carrington, a case considered a monument of English freedom. Entick expressly declared every person’s property sacred and prohibited anyone from setting foot upon a neighbor’s close without permission. Hence, any intrusion is trespass and must have a legal justification. Similarly, the Fourth Amendment underlines the close connection to property by including the phrase “in their persons, houses, papers, and effects.” Thus, the guarantee against unreasonable searches guided the Court’s decision because it believed that the Fourth Amendment must provide the degree of protection afforded when it was drafted.
Holding
The US Supreme Court affirmed the decision of the Court of Appeals that the lengthy monitoring of Jones constituted a search under the Fourth Amendment. The Appeals Court for the DC Circuit had reversed the jury guilty verdict and sentence to life imprisonment, noting that the admission of evidence acquired by warrantless use of the GPS device violated the Fourth Amendment. Hence, upon granting certiorari, the US Supreme Court, as read by Justice Scalia, agreed with the majority decision for the affirmation of the earlier ruling.
Reasoning
The Court examined the Government’s contention that Katz v. United States provided a standard showing there was no search in Jones. The argument was that Jones did not have any reasonable expectation of privacy in the Jeep’s underbody, where the device was attached, and the locations on the public roads visible to all. Hence, the Court argued that Jones’ Fourth Amendment did not rise or fall with the Katz formulation, which stated that the privacy principle only applied to people, not places. Besides, Katz had introduced the reasonable expectation of privacy standard. Therefore, the Court determined that the Harlan standard did not repudiate the understanding that the Fourth Amendment embodied the concern for government trespass on the persons, houses, papers, and effects it enumerates. Moreover, Justice Scalia outlined that based on Soldal v. Cook County, the Fourth Amendment does not use property rights as the sole measure for reasonable searches and seizures. Thus, the reasonable expectation of privacy test did not replace but complemented the common-law trespass standard.
Moreover, the Court’s reasoning, as expressed in Justice Sotomayor’s concurrence, indicates that the decision was guided by the privacy of a person’s property. The Court argued that the Fourth Amendment contemplated a search as the occasion the Government obtains information by physical intrusion on a constitutionally protected area. Therefore, the officers installed a GPS tracking device on Jones’ Jeep without obtaining a valid warrant and without Jones’ consent. The Government then used the device to monitor the Jeep’s movements, which constituted a usurpation of private property to conduct surveillance. Thus, the Court found the action as meeting the threshold for the invasion of privacy interests the Fourth Amendment affords and protects. The Court reasoned further that the Amendment is not only concerned with trespassory intrusions on privacy. It found that the Government violated the subjective expectation of privacy recognized societally as reasonable.
Critical Analysis
Fourth Amendment cases are significant in defining the constitutionality of Government actions regarding the intrusion into individuals’ property. Titus and Olson argue that four months before the determination of US v. Jones, a panel of distinguished lawyers, journalists, and law professors deliberated on the prevailing Supreme Court precedent (243). They voted unanimously to declare that warrantless intrusion of privacy did not exist and there was no such violation. Hence, the event at the William and Mary School of Law indicated that legal experts and the public were interested in the use of governmental authority when pursuing cases against individuals. Americans significantly value privacy and the right of property and cases touching specifically on the matters attract their interests. Therefore, the decision in US v. Jones was a welcome clarification and check on the Government’s powers on searches and seizures of private property, entailing the components of the persons, houses, papers, and effects, as per the Fourteenth Amendment. In other words, the Court heard the case because of the particular interest of experts and the public, as a matter of national and constitutional significance.
Additionally, United States v. Jones overturned prior tracking cases that relied on the Katz v United States on the individual’s reasonable expectation of privacy. Thompson II argues that the area to be searched has always been a subject for contention in determining cases (1). Hence, the Court clarified Katz because the police, in Jones, had physically invaded property to attach the GPS device, unlike in past cases. The Court declined the Katz reasoning and chose the trespass theory to decide whether there was any physical intrusion onto a constitutionally protected area and the attempt to obtain information (Thompson II 1). Thus, the Court relied on the more limited test because it had to define whether a test had occurred, which had happened in the Jones case. The case marks a significant turning point in redefining governmental surveillance techniques, specifically on the installation of GPS tracking devices. The decision also reinforces the significance of the Fourteenth Amendment in offering privacy protections against government intrusion.
Moreover, the case presented a historic opportunity for the Court to consider its jurisprudence on the Fourteenth Amendment issues. Titus and Olson assert that Jones granted the Court the benefit of an amicus brief urging it to reconsider the rationale for the prevailing precedent regarding the reasonable privacy expectations (245). The basis was on the property-based provision of the Fourteenth Amendment and the need to restore to the earlier jurisprudence for protecting the sanctity of private property and the people’s civil sovereignty. Hence, the amicus sought the Court to discard the modern test concerning the reasonable expectation of privacy and return the Amendment to the textual and historic private property protection (Titus and Olson 246). The Court acknowledged the opportunity and accepted to discuss the property issue, which was a matter of interest for legal and other experts and the American public. Thus, the case was significant because it offered an alternative that used the trespass principle instead of the privacy test.
Based on the brief and critical analysis, it is evident that for a police officer, it is important that any investigation considers the legal standards that will not negate a case. For instance, there is a need for obtaining the right authorization to intrude onto constitutionally protected areas. Adherence to the standard is important in safeguarding any evidence gathered because the information must be admissible before a court. Besides, the police officer must be wary of infringing on the Americans’ civil rights as it is a loophole for the defense to challenge any accusations. Therefore, investigations need to follow the right processes to ensure criminals do not escape punishment.
Works Cited
Newton, Brent E. “The Supreme Court’s Fourth Amendment Scorecard.” Stan. JCR & CL 13 (2017): 1. https://law.stanford.edu/wp-content/uploads/2017/12/newton.pdf
Thompson II, Richard M. United States v. Jones: GPS Monitoring, Property, and Privacy. Congressional Research Service, 2012. https://fas.org/sgp/crs/misc/R42511.pdf
Titus, Herbet W., and William J. Olson. “United States v. Jones: Reviving the Property Foundation of the Fourth Amendment.” Case W. Res. JL Tech. & Internet 3 (2012): 243. https://scholarlycommons.law.case.edu/cgi/viewcontent.cgi?article=1029&context=jolti
US v. Jones, 132 S. Ct. 945, 565 U.S. 400, 181 L. Ed. 2d 911 (2012). https://scholar.google.com/scholar_case?case=6122276400056758151&q=United+States+v.+Jones&hl=en&as_sdt=2003&as_ylo=2012&as_yhi=2013