United States v. Davis
By Constance C. Hodges
In United States v. Davis, the United States Court of Appeals for the Eleventh Circuit, as a matter of first impression, addressed a defendant’s Fourth Amendment standing to challenge a geofence warrant. Johnnie Davis was convicted on three counts of carjacking in Montgomery, Alabama, in violation of 18 U.S.C. § 2119. Davis appealed his conviction, arguing that the district court erred in denying his motions to suppress both evidence obtained from a geofence warrant and his post-arrest inculpatory statements. Additionally, Davis argued the district court erred by not granting his motion for judgment of acquittal.
Between 2014 and 2017, the Montgomery Police Department (MPD) was investigating thirty-five incidents of robberies and carjackings that occurred near Montgomery, Alabama. During this investigation, MPD collaborated with the Federal Bureau of Investigation (FBI) through the help of Nathan Faggert, who was both a Sergeant with the MPD and task force officer with the FBI. The FBI was primarily responsible for gathering digital information “while the MPD responded to robberies, interviewed witnesses, and developed leads.” During the investigation, three more carjackings occurred on January 23rd, 2020, October 30th, 2020, and November 11th, 2020.
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