U.S. v. Martin

In prosecution on drug trafficking charge, Dist. Ct. did not err in denying defendant’s motion to suppress evidence, even though police obtained said evidence following their warrantless placement of GPS tracking device on defendant’s car, which, at time of trial, was deemed “search” for purposes of 4th Amendment under Jones, 132 S.Ct. 945. At time of placement of GPS device, Garcia (474 F.3d 994) was controlling precedent, which allowed instant officers to use GPS device to track defendant’s movements without necessity of obtaining warrant to do so. Ct. rejected defendant’s claim that officers could not use Garcia to support their actions, even though officers made no prior attempt to determine legality of placing GPS device on defendant’s car. Ct. also found that officers’ lack of subjective awareness of Garcia was irrelevant, since applicable law regarding GPS placement had been settled at time of said placement.