United States v. Knotts

460 U.S. 276 (1983)

Facts

Narcotics investigators were notified that a former 3M employee, had been stealing chemicals which could be used in manufacturing illicit drugs. Visual surveillance of Armstrong (D) revealed that, after leaving the employ of 3M Co., he had been purchasing similar chemicals from the Hawkins Chemical Co. in Minneapolis. D delivered the chemicals to Petschen. (D1). Officers installed a beeper inside a five-gallon container of chloroform. Officers followed D using both visual surveillance and a monitor which received the signals sent from the beeper. The container was transferred to D1's automobile, and they continued their pursuit. They eventually followed it to Knotts' (D2) cabin. They put the cabin under intermittent visual surveillance for three days and then secured a search warrant. They discovered a fully operable, clandestine drug laboratory in the cabin finding formulas for amphetamine and methamphetamine, over $10,000 worth of laboratory equipment, and chemicals in quantities sufficient to produce 14 pounds of pure amphetamine. They also located the five-gallon container of chloroform. D2s' motion to suppress evidence based on the warrantless monitoring of the beeper was denied. D2 was convicted for conspiring to manufacture controlled substances. A divided panel of the Eighth Circuit reversed the conviction, finding that the monitoring of the beeper was prohibited by the Fourth Amendment because its use had violated D2's reasonable expectation of privacy and that all information derived after the location of the cabin was a fruit of the illegal beeper monitoring. The Supreme Court granted certiorari.