Pennsylvania district court suppresses GPS evidence

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.