United States v. Knotts

In United States v. Knotts, 460 U.S 276 (1983), law enforcement agents arranged with a seller of chloroform to install a beeper in a container of chloroform purchased by respondent Knotts' codefendant, since law enforcement suspected that the codefendant was purchasing chloroform to manufacture drugs. After Knotts' codefendant purchased the container of chloroform containing the beeper and placed it in his vehicle, law enforcement followed the car and traced the vehicle's movements by visual surveillance and a monitor that received the beeper signals contained in the container. Law enforcement then traced the chloroform to Knotts' cabin by beeper signal alone. Law enforcement subsequently obtained a search warrant for respondent's residence and discovered the chloroform container as well as other evidence. (Knotts, 460 US 276.) In connection with Knotts' challenge to the use of the beeper to monitor the chloroform container, the Supreme Court held that the monitoring of a beeper placed in a container in defendant's vehicle was not a search and seizure within the meaning of the Fourth Amendment since defendant had no legitimate expectation of privacy in the monitoring of the vehicle on public streets and thoroughfares. The Court stated that the surveillance conducted in Knotts amounted to the following of an automobile on public streets and highways and that there is a diminished expectation of privacy with regard to automobiles: "One has a lesser expectation of privacy in a motor vehicle because its function is transportation and it seldom serves as one's residence or as the repository of personal effects. A car has little capacity for escaping public scrutiny. It travels public thoroughfares where both its occupants and its contents are in plain view." (Knotts, 460 US 281, internal quotation marks omitted], quoting Cardwell v. Lewis, 417 US 583, 590, 94 S Ct 2464, 2469, 41 LE2d 325 [1974].) In short, the Supreme Court in Knotts stated that a person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another. (Id.)