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Keywords

defendantdiscoveryappealtrialmotionseizure
appealtrialmotionappellantseizure

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Jones v. United States, 168 A.3d 703

Facts

Defendant Prince Jones was convicted of multiple offenses, including first-degree sexual abuse and robbery. The police used a cell-site simulator to locate his phone without a warrant, which led to his arrest and the recovery of evidence. The trial court denied Jones's motion to suppress the evidence, citing the inevitable-discovery doctrine, but the appellate court found that the use of the simulator violated his Fourth Amendment rights.

A jury found appellant Prince Jones guilty of various offenses arising out of two alleged incidents of sexual assault and robbery at knifepoint. Mr. Jones appeals his convictions on the ground that much of the evidence offered against him at trial was the direct or indirect product of a warrantless—and thus, Mr. Jones argues, unlawful—search involving a cell-site simulator or 'stingray.'

Issue

Did the use of a cell-site simulator to locate the defendant's cell phone constitute a search under the Fourth Amendment, and was the evidence obtained as a result admissible?

Mr. Jones claims that the government's use of a cell-site simulator violated his Fourth Amendment rights and that the trial court erred in failing to grant his motion to suppress.

Rule

The use of a cell-site simulator constitutes a search under the Fourth Amendment if it invades a reasonable expectation of privacy. Evidence obtained from an unlawful search is generally inadmissible unless it falls under specific exceptions, such as the inevitable-discovery doctrine or the good-faith exception.

The Fourth Amendment protects the 'right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures,' and thus we turn first to the threshold question whether the government's use of the cell-site simulator to locate Mr. Jones's cellphone constituted a search or seizure.

Analysis

The court determined that the use of the cell-site simulator invaded Jones's reasonable expectation of privacy, as it allowed the police to locate him without a warrant. The court rejected the government's claims that the evidence was admissible under the inevitable-discovery doctrine, finding that the lawful process to locate Jones's phone had not commenced before the unlawful seizure. Additionally, the good-faith exception was deemed inapplicable because the police did not act under a valid warrant or legal authority.

The preceding considerations lead us to conclude that the use of a cell-site simulator to locate Mr. Jones's phone invaded a reasonable expectation of privacy and was thus a search.

Conclusion

The appellate court reversed the trial court's ruling and remanded the case, concluding that the evidence obtained from the cell-site simulator was inadmissible due to the violation of Jones's Fourth Amendment rights.

The government's use of the cell-site simulator to locate Mr. Jones was therefore a search. The government did not obtain a warrant and has not argued that the search 'f[ell] within a specific exception to the warrant requirement,' and therefore the search was unlawful under the Fourth Amendment.

Who won?

Prince Jones prevailed in the appeal because the court found that the government's use of the cell-site simulator constituted an unlawful search, rendering the evidence obtained inadmissible.

The appellate court found that the use of a cell-site simulator to locate Mr. Jones's cellphone constituted a search under the Fourth Amendment, and the evidence obtained from the unlawful use of the simulator was inadmissible.

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