Eleventh Circuit Court of Appeals - Published Opinions

Thursday, December 03, 2020

Watkins: Reversing Order Granting Suppression Based on the Inevitable Discovery Exception

In United States v. Watkins, No. 18-14336 (Dec. 3, 2020) (Ed Carnes, Luck, Marcus), the Court reversed an order granting the defendant’s motion to suppress on the government’s appeal.

The government conceded that it violated the Fourth Amendment when a GPS tracking device placed inside an intercepted package re-activated inside the defendant’s home.  However, the Court concluded that the inevitable discovery exception to the exclusionary rule applied.  The Court reasoned that, based on leads and evidence already in the agents’ possession, there was a reasonable probability that the evidence would have inevitably been discovered because the agents would have conducted the same knock and talk with the same result.  The district court erroneously disregarded the magistrate judge’s credibility findings without holding a new hearing.