Context:

Police and the chemical company 3M were suspicious that Tristan Armstrong was stealing chloroform to illegally produce methamphetamine. Armstrong had also purchased the same chemical from Hawkins Chemical Company. With the consent from Hawkins Chemical

Company, the government placed a radio transmitter device (beeper) on a drum of chloroform that was being delivered to Armstrong, who then shipped it along to two other people, eventually arriving at Leroy Knotts’ cabin. The police obtained a search warrant for the cabin with the transmitter’s data and found a methamphetamine lab. Knotts moved to have the evidence gathered from the radio transmitter suppressed, which was denied. Knotts had his trial court conviction overturned by the appellate court, which ruled that the radio transmitter violated the Fourth Amendment protection against unlawful searches and seizures. The Supreme Court unanimously decided that the radio transmitter could be used legally to track a vehicle, as someone could easily follow a car to record the same information, however it would take much longer. The reasonable expectations of privacy that an individual have for their vehicle are far fewer than the reasonable expectations of privacy in someone's home or dwelling, including their movements of the car, which are in essence public. In U.S. v. Jones (2012), the court narrowed the Knotts decision when they ruled unanimously against the government, who placed a GPS device on a car to track a suspect’s movements for 4 weeks.

United States v. Knotts

460 U.S. 276 (1983)

(The Beeper Case)


Facts:

Suspicion attached to this trio when the 3M Co., which manufactures chemicals in St. Paul, notified a narcotics investigator for the Minnesota Bureau of Criminal Apprehension that Armstrong, a former 3M employee, had been stealing chemicals which could be used in manufacturing illicit drugs. Visual surveillance of Armstrong revealed that after leaving the employ of 3M Co., he had been purchasing similar chemicals from the Hawkins Chemical Co. in Minneapolis. The Minnesota narcotics officers observed that after Armstrong had made a purchase, he would deliver the chemicals to codefendant Petschen.

With the consent of the Hawkins Chemical Co., officers installed a beeper inside a five-gallon container of chloroform, one of the so-called "precursor" chemicals used to manufacture illicit drugs. Hawkins agreed that when Armstrong next purchased chloroform, the chloroform would be placed in this particular container. When Armstrong made the purchase, officers followed the car in which the chloroform had been placed, maintaining contact by using both visual surveillance and a monitor which received the signals sent from the beeper.

Armstrong proceeded to Petschen's house, where the container was transferred to Petschen's automobile. Officers then followed that vehicle eastward towards the state line, across the St. Croix River, and into Wisconsin. During the latter part of this journey, Petschen began making evasive maneuvers, and the pursuing agents ended their visual surveillance. At about the same time officers lost the signal from the beeper, but with the assistance of a monitoring device located in a helicopter the approximate location of the signal was picked up again about one hour later. The signal now was stationary and the location identified was a cabin occupied by respondent near Shell Lake, Wis. The record before us does not reveal that the beeper was used after the location in the area of the cabin had been initially determined.

Relying on the location of the chloroform derived through the use of the beeper and additional information obtained during three days of intermittent visual surveillance of respondent's cabin, officers secured a search warrant. During execution of the warrant, officers discovered a fully operable, clandestine drug laboratory in the cabin. In the laboratory areaofficers found formulas for amphetamine and methamphetamine, over $10,000 worth of laboratory equipment, and chemicals in quantities sufficient to produce 14 pounds of pure amphetamine. Under a barrel outside the cabin, officers located the five-gallon container of chloroform.

United States v. Knotts 460 U.S. 276 (1983) 

United States v. Knotts 460 U.S. 276 (1983) 

Question:

Whether such use of a beeper violated respondent's rights secured by the Fourth Amendment.

Reasoning:

The governmental surveillance conducted by means of the beeper in this caseamounted principally to the following of an automobile on public streets and highways. We have commented more than once on the diminished expectation of privacy in an automobile.

A person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another. When Petschen traveled over the public streets he voluntarily conveyed to anyone who wanted to look the fact that he was traveling over particular roads in a particular direction, the fact of whatever stops he made, and the fact of his final destination when he exited from public roads onto private property.

Respondent Knotts, as the owner of the cabin and surrounding premises to which Petschen drove, undoubtedly had the traditional expectation of privacy within a dwelling place insofar as the cabin was concerned. But no such expectation of privacy extended to the visual observation of Petschen's automobile arriving on his premises after leaving a public highway, nor to movements of objects such as the drum of chloroform outside the cabin in the "open fields."

Visual surveillance from public places along Petschen's route or adjoining Knotts' premises would have sufficed to reveal all of these facts to the police. The fact that the officers in this caserelied not only on visualsurveillance,but also on the use of the beeper to signal the presence of Petschen's automobile to the police receiver, does not alter the situation. Nothing in the Fourth Amendment prohibited the police from augmenting the sensory faculties bestowed upon them at birth with such enhancement as science and technology afforded them in this case.

Nothing in this record indicates that the beeper signal was received or relied upon after it had indicated that the drum containing the chloroform had ended its automotive journey at rest on respondent's premises in rural Wisconsin. Admittedly, because of the failure of the visual surveillance, the beeper enabled the law enforcement officials in this caseto ascertain the ultimate resting place of the chloroform when they would not have been able to do so had they relied solely on their naked eyes. But scientific enhancement of this sort raises no constitutional issues which visual surveillance would not also raise. A police car following Petschen at a distance throughout his journey could have observed him leaving the public highway and arriving at the cabin owned by respondent, with the drum of chloroform still in the car. This fact, along with others, was used by the government in obtaining a search warrant which led to the discovery of the clandestine drug laboratory. But there is no indication that the beeper was used in any way to reveal information as to the movement of the drum within the cabin, or in any way that would not have been visible to the naked eye from outside the cabin.

Justice Rehnquist decides United States v. Knotts

Holding:

Monitoring the beeper signals did not invade Knott's REP, and thus there was neither a "search" nor a "seizure" under the 4th Amendment.v


Name
Name
Is there anything we left out? Anything we should remove? Let us know your thoughts!

 
 

Key Takeaway

Nothing in 4thAamendment prohibits the police from augmenting the sensory faculties bestowed upon them at birth with such enhancement as science and technology afforded them while tracking someone on public roads because that information could have been acquired through observation in publicly navigable spaces.          


Court Syllabus:

Having reason to believe that one Armstrong was purchasing chloroform to be used in the manufacture of illicit drugs, Minnesota law enforcement officers arranged with the seller to place a beeper (a radio transmitter) inside a chloroform container that was sold to Armstrong. Officers then followed the car in which the chloroform was placed, maintaining contact by using both visual surveillance and a monitor which received the beeper signals, and ultimately tracing the chloroform, by beeper monitoring alone, to respondent's secluded cabin in Wisconsin. Following three days of intermittent visual surveillance of the cabin, officers secured a search warrant and discovered the chloroform container, and a drug laboratory in the cabin, including chemicals and formulas for producing amphetamine. After his motion to suppress evidence based on the warrantless monitoring of the beeper was denied, respondent was convicted in Federal District Court for conspiring to manufacture controlled substances in violation of 21 U. S. C. § 846. The Court of Appeals reversed, holding that the monitoring of the beeper was prohibited by the Fourth Amendment.

Held: Monitoring the beeper signals did not invade any legitimate expectation of privacy on respondent's part, and thus there was neither a "search" nor a "seizure" within the contemplation of the Fourth Amendment. The beeper surveillance amounted principally to following an automobile on public streets and highways. A person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements. While respondent had the traditional expectation of privacy within a dwelling place insofar as his cabin was concerned, such expectation of privacy would not have extended to the visual observation from public places of the automobile arriving on his premises after leaving a public highway, or to movements of objects such as the chloroform container outside the cabin. The fact that the officers relied not only on visual surveillance, but also on the use of the beeper, does not alter the situation. Nothing in the Fourth Amendment prohibited the police from augmenting their sensory faculties with such enhancement as science and technology afforded them in this case. There is no indication that the beeper was used in any way to reveal information as to the movement of the chloroform container within the cabin, or in any way that would not have been visible to the naked eye from outside the cabin.


How the Justices Voted

Majority: Rehnquist, joined by Burger, White, Powell, O'Connor

Concurrence: Brennan, joined by Marshall

Concurrence: Blackmun, joined by Brennan, Marshall, Stevens

Concurrence: Stevens, joined by Brennan, Marshall