Lewis v. State

Summary

The Court affirmed the denial of Lewis’s motion to suppress and his convictions, holding that the affidavits supporting the four GPS warrants established probable cause under the totality of the circumstances. The warrants were not facially invalid because they required installation of the tracking devices within Delaware, while Lewis’s separate arguments concerning out-of-state monitoring were either not preserved or not properly presented on appeal. The Court therefore declined to decide whether Delaware police may continuously monitor a properly installed GPS device after a vehicle leaves the State.