U.S. v. Rainone

In prosecution on charge of unlawful possession of firearm, Dist. Ct. did not err in denying defendant’s motion to suppress firearm found in defendant’s residence after police placed GPS device on defendant’s vehicle without having previously obtained warrant. While Supreme Ct. in Jones, 132 S.Ct. 945 (2012), found that placement of GPS device on vehicles without search warrant or defendant’s consent violated 4^th Amendment, good-faith exception to exclusionary rule applied in instant case, since 7^th Circuit precedent allowed placement of GPS device on suspect’s vehicle without warrant in 2009, when instant GPS device was attached to defendant’s vehicle. Ct. also did not err in giving joint possession instruction to jury, where record showed that several individuals had potential access to defendant’s bedroom where gun was found.