People v. LeFlore

Defendant, who was convicted of aggravated robbery, robbery, and burglary, had filed pretrial motion to quash arrest and suppress evidence, arguing that police improperly used a GPS device without a warrant to track movements of a vehicle he used. Even where a fourth amendment violation has occurred, evidence that resulted will not be suppressed when good-faith exception to exclusionary rule applies. In this case, good-faith exception to exclusionary rule applies, and evidence obtained against Defendant should not be excluded. At time when detective placed GPS on vehicle in April 2009, U.S. Supreme Court's decisions were "binding appellate precedent" that detective could have reasonably relied upon. In the alternative, it would have been objectively reasonable for police to rely upon legal landscape and constitutional norm in existence at time of search that allowed warrantless attachment and use of GPS technology. (GARMAN, KILBRIDE, and KARMEIER, concurring; BURKE, FREEMAN, and THEIS, dissenting.)