I won't continue to belabor the details of these cases unnecessarily, but in United States v. Ortiz, 2012 U.S. Dist. LEXIS 101245 (E.D. Pa. 2012), the district court held that pre-Jones GPS evidence violated the Fourth Amendment and does not fall under the Davis good faith rule.
Law enforcement used two GPS devices in the investigation - one for about a month and the second for two weeks. The second device led to the discovery of $2.3 million in suspected drug money.
UPDATE: Professor Orin Kerr has written about Ortiz on Volokh Conspiracy, discussing how judges should draft warrants to ensure compliance with the Fourth Amendment.
Thursday, July 26, 2012
Pennsylvania district court suppresses GPS evidence
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