N.D.Ind.: State court GPS tracking order limited to Indiana didn’t prevent FBI from using it under 4A when car went to California

Defendant was suspected of a bank robbery, and the government presented a GPS tracking warrant affidavit to an Indiana judge to track defendant in Indiana. Shortly thereafter, defendant drove to Los Angeles, and he was stopped for a traffic offense in Nebraska. Concerned that might interfere with their investigation, the FBI tried to check on what was going on in Nebraska and to photograph the inside of the car. Defendant got a warning ticket and continued on to LA and stopped near a bank. The FBI figured rightly that defendant was casing a bank to rob, and, sure enough, he did and they caught him. The tracking of the GPS to LA was not a violation of the Fourth Amendment, following United States v. Castetter, 865 F.3d 977 (7th Cir. 2017) (posted here). United States v. Brewer, 2017 U.S. Dist. LEXIS 201509 (N.D. Ind. Dec. 7, 2017).

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