&sq=Envato&lang=en&file=File:Wiki_letter_w.svg){kind=small} | This article's lead section may be too short to adequately summarize the key points. (December 2014) |
| United States v. Davis | |
|---|---|
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| Court | United States Court of Appeals for the Eleventh Circuit |
| Full case name | United States v. Quartavious Davis |
| Decided | May 5, 2015 |
| Citation | No. 12-12928; 785 F.3d 498 (11th Cir. 2015) |
| Case history | |
| Prior history | Mot. to suppress denied, D.C. Docket No. 1:10-cr-20896-JAL-2; Affirmed, 754 F.3d 1205 (11th Cir.); rehearing en banc granted, opinion vacated, 573 F. App'x 925 (11th Cir. 2014) |
| Appealed from | United States District Court for the Southern District of Florida |
| Subsequent history | Cert. denied, Supreme Court |
United States v. Quartavious Davis is a United States federal legal case that challenged the use in a criminal trial of location data obtained without a search warrant from MetroPCS, a cell phone service provider. Mobile phone tracking data had helped place the defendant in this case at the scene of several crimes, for which he was convicted. The defendant appealed to the Eleventh Circuit Court of Appeals, which found the warrantless data collection had violated his constitutional rights under the Fourth Amendment to the United States Constitution, but declined to order a new trial because the evidence was collected in good faith.[1] The Eleventh Circuit has since vacated this decision pending a rehearing by the Eleventh Circuit en banc. United States v. Davis, 573 Fed. Appx. 925 (11th Cir. 2014). On 5 May 2015, the en banc order upheld the use of the information.[2] On 9th Nov 2015, the Supreme Court of the United States declined to hear this case on appeal.[3]
Quartavious Davis, on trial with five co-defendants, was convicted on several counts of Hobbs Act robbery, conspiracy, and knowing possession of a firearm in furtherance of a crime of violence and sentenced to over 161 years in prison. He appealed on several grounds, principally arguing that the court admitted stored cell site location information obtained without a warrant, in violation of his Fourth Amendment rights. The government had obtained the data under a provision of the Stored Communications Act that only requires showing "that there are reasonable grounds to believe that the... records or other information sought, are relevant and material to an ongoing criminal investigation." (18 U.S.C. § 2703(d)). That provision does not require showing probable cause, which would have been needed for a warrant.[4]
- ^ Jacob Kastrenakes (11 June 2014). "Warrantless cellphone location tracking is illegal, US circuit court rules". theverge.com. Vox Media, Inc. Retrieved 14 June 2014.
- ^ United States v. Quartavious Davis (11th Cir. 5 May 2015), Text.
- ^ Ruger, Todd. "Supreme Court Passes on Cell Phone Tracking Case". Roll Call. Retrieved 2015-11-10.
- ^ David Bryan Sentelle, C.J. (11 June 2014). "United States of America v. Quartavious Davis – No. 12-12928 – D.C. Docket No. 1:10-cr-20896-JAL-2" (PDF). Retrieved 2014-12-14.