U.S. v. Brown

In prosecution on drug conspiracy charge, Dist. Ct. did not err in failing to suppress evidence obtained from police through use of GPS device that police had installed on consenting informant’s vehicle. While Supreme Court in Jones, 132 S.Ct.945 (2012) found that police installation of GPS device was “search” that was valid only if reasonable, Ct. of Appeals found that regardless of whether instant police monitoring of GPS device was “search,” exclusionary rule would not apply to suppress instant evidence since, prior to Jones, existing case law would have led police to believe that installation of GPS device on consenting informant’s vehicle was not search, and thus was permissible.