Comparing the Supreme Court Judgments in United States vs. Knotts and United States v. Karo Essay

Comparing the Supreme Court Judgments in United States vs.

Knotts and United States v. Karo

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In this paper I am going to compare and contrast the Supreme Court decisions in the two cases dealing with Forth Amendment to the American Constitution guarding individuals against unreasonable search and seizures. Both cases refer to limits of terms “unreasonable search and seizure”. I am going to examine the reasoning applied by court in each of the cases and demonstrate that although the facts of the case differ, the Court’s rationale in each case was virtually the same.

There are several principal differences in the facts of the case. First, in the United States vs. Knotts a beeper was placed into container that later moved only inside of respondents vehicle, while in United States v. Karo the beeper moved from one private house to another until it arrived to a store. Considering that the Fourth amendment grants a right to be secure in “persons, houses, papers, and effects”, the United States vs. Knotts is formally much less tied to the constitutional provisions than United States v. Karo since in the latter case the beeper provided information about movement of cans between private houses and about effects of multiple individuals, while in the first case information was revealed about one person and his vehicle.

In both cases the Supreme Court arrived to conclusion that placing a beeper inside a can was not a violation of the Fourth Amendment since it merely provided information about movement of cans and did not reveal any other information of individual’s private life. At that, using a beeper for observation was actually equated to outside observation. The Court noted that “the beeper enabled the law enforcement officials in this case to ascertain the ultimate resting place of the chloroform when they would not have been able to do so had they relied solely on their naked eyes. But scientific enhancement of this sort raises no constitutional issues which visual surveillance would not also raise” (United States vs. Knotts. 460 US 276) and “since the movements of the automobile and the arrival of the can containing the beeper in the area of the cabin could have been observed by the naked eye, no Fourth Amendment violation was committed by monitoring the beeper during the trip to the cabin” (United States v. Karo. 468 US 713). At that, the Court directly referred to United States vs. Knotts as a precedent for its reasoning.

To my opinion, such Court’s reasoning in United States v. Karo was not quite correct. In United States vs. Knotts a beeper was indeed simply an addition to outside surveillance that could be performed with naked eyes. In United States v. Karo the beeper provided information not only about the can itself, but also about individual’s contacts with other persons as well as his effects and transactions. It was not an amendment to “naked eyes”, since the DEA would never obtain information it has obtained without a beeper. However, I agree that no violation of the Fourth Amendment occurred in each of the cases. The term “search” supposes that a premise is entered without owner’s consent, so that his or her private life is essentially affected. “Seizure” means taking individual’s property under court’s order and without consent of this individual. Neither of these situations can be observed in the case, since in both cases every piece of information could be obtained by outside observation, although in both cases the police failed to make such observations without a beeper.

It should be kept in mind that the Supreme Court does not alter or amend the Constitution. It simply interprets Constitutional provision and makes them applicable to particular cases. In United States vs. Knotts and United States v. Karo the Court merely explained that the Fourth Amendment is not applicable technical means like beepers and equated such means to outside observation. However, the Fourth Amendment has not been changed in any way.


1. United States v. Knotts, 460 U.S. 276 (1983). Retrieved July 26, 2009;

2. United States v Karo, 468 U.S. 705 (1984) Retrieved July 26, 2009.


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