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United States v. Baez – Case Brief Summary (Federal Court)

In United States v. Baez, 878 F. Supp. 2d 288 (D. Mass. 2012), the court, located in the First Circuit, applied the good faith exception to a placement of a GPS device on a vehicle for 347 days.

The court stated there was no split in the federal circuits prior to Maynard and even though that case was filed prior to the search in Baez, it was filed only three days before and, thus, insignificant to the analysis.

The court concluded that "binding" within the meaning of the Davis good faith exception should not be applied literally and a substantial consensus among precedential courts is sufficient.