United States v. Knotts
460 U.S. 276 (1983)
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Rule of Law:
The monitoring of a beeper device in a container, which allows law enforcement to trace the container's movement on public roads to its destination on private property, does not constitute a search or seizure under the Fourth Amendment because a person has no reasonable expectation of privacy in their movements on public thoroughfares.
Facts:
- Tristan Armstrong, a former 3M employee, was suspected of stealing chemicals used to manufacture illicit drugs.
- Police observed Armstrong purchasing similar chemicals from Hawkins Chemical Co. and delivering them to his codefendant, Darryl Petschen.
- With the consent of Hawkins Chemical Co., police installed a radio transmitter (a beeper) inside a five-gallon container of chloroform.
- Hawkins Chemical then sold this specific, bugged container of chloroform to Armstrong.
- Armstrong drove to Petschen's house, where the container was transferred to Petschen's vehicle.
- Police tracked Petschen's vehicle as it traveled on public highways from Minnesota into Wisconsin.
- After Petschen began driving evasively, officers lost visual contact but continued to track the beeper signal via a helicopter.
- The beeper signal became stationary at a secluded cabin owned by respondent Knotts, where the container came to rest.
Procedural Posture:
- Based on the beeper's location and other information, officers obtained a search warrant for Knotts' cabin, where they discovered a drug laboratory.
- Knotts was charged in the U.S. District Court for the District of Minnesota with conspiracy to manufacture controlled substances.
- Knotts filed a motion to suppress evidence derived from the beeper, which the trial court denied.
- Following a trial, Knotts was convicted.
- Knotts, as appellant, appealed his conviction to the U.S. Court of Appeals for the Eighth Circuit.
- A divided panel of the Eighth Circuit reversed the conviction, finding the beeper monitoring violated the Fourth Amendment.
- The United States, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does the monitoring of a beeper signal, which allows police to track the movement of a person driving on public highways and to locate the item on private property, constitute a search or seizure under the Fourth Amendment?
Opinions:
Majority - Justice Rehnquist
No. The monitoring of a beeper signal to track movement on public thoroughfares is not a search under the Fourth Amendment. A person has a diminished expectation of privacy in an automobile and voluntarily conveys their movements on public roads to anyone who wishes to observe. The use of a beeper to follow Petschen's car on public highways did not reveal any information that could not have been obtained through visual surveillance. The beeper merely augmented the sensory faculties of the police, which is not constitutionally prohibited. While Knotts had a reasonable expectation of privacy inside his cabin, the beeper was not used to reveal information about the movement of the drum within the cabin; it only identified the location where the journey ended, a fact that could have been observed from outside the property.
Concurring - Justice Brennan
Yes, I concur in the judgment. While the monitoring of the beeper in this specific instance was not a Fourth Amendment violation, the case would have been more difficult if the respondent had challenged the beeper's initial installation. When the government physically intrudes into a constitutionally protected area to obtain information, it may constitute a violation even if the information could have been obtained by other means. The act of purposefully arranging for a suspect to be sold an object with a beeper already installed inside it raises significant Fourth Amendment questions that are not addressed by the majority.
Concurring - Justice Blackmun
Yes, I concur in the judgment. The Court's opinion unnecessarily refers to the 'open fields' doctrine from Hester v. United States. This case does not concern that doctrine, and any discussion of it is gratuitous, especially since the Court has already granted certiorari in other cases that directly address the scope of the open fields doctrine. Deference should be given to decide that issue in a case where it is properly briefed and argued.
Concurring - Justice Stevens
Yes, I concur in the judgment. I do not join the Court's opinion because it contains two unnecessarily broad dicta. First, it distorts the record by implying the chloroform drum was in 'open fields' when the record does not support this. Second, the Court's suggestion that the Fourth Amendment does not inhibit police from augmenting their senses with any technology is contrary to the holding in Katz v. United States. While the augmentation in this case was unobjectionable, the use of more advanced electronic detection techniques could implicate sensitive constitutional concerns.
Analysis:
This decision established a key principle for surveillance technology under the Fourth Amendment: monitoring that which is exposed to the public is not a search. By focusing on the lack of a reasonable expectation of privacy for movements on public roads, the Court distinguished this type of electronic tracking from the auditory eavesdropping into a private space in Katz. This case set a crucial precedent, creating a dividing line between permissible surveillance of public activity and impermissible intrusion into private spaces. It paved the way for future legal challenges involving more advanced and persistent technologies like GPS tracking, which would later force the Court to reconsider the limits of this 'public exposure' doctrine.
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