The U.S. Court of Appeals for the Seventh Circuit affirmed the drug trafficking conviction of Antonio Carrazco-Martinez on February 5, 2026, rejecting his constitutional challenge to government surveillance methods that included cell-site simulators and hidden cameras.
Carrazco-Martinez was suspected of participating in a drug trafficking operation based in Chicago with connections to Mexico. The Drug Enforcement Agency launched its investigation in May 2020, according to court records. Federal agents obtained warrants authorizing the use of sophisticated surveillance technology to gather evidence against Carrazco-Martinez and his associates.
The government employed two key surveillance methods in the investigation. First, agents used a cell-site simulator, a device that mimics cell phone towers to track mobile devices and intercept communications. Second, they installed a closed-circuit television camera in the garage of a house where Carrazco-Martinez and his associates allegedly packaged and distributed illegal drugs and proceeds from their operation.
Following the investigation, federal prosecutors charged Carrazco-Martinez with participating in a narcotics distribution conspiracy under 21 U.S.C. § 846 and possessing with intent to distribute cocaine and heroin under 21 U.S.C. § 841(a). The charges stemmed from evidence gathered through the warrant-authorized surveillance operations.
Carrazco-Martinez mounted a vigorous defense, filing motions to suppress evidence obtained from both the cell-site simulator and the CCTV camera. His legal team argued that the surveillance violated his Fourth Amendment rights against unreasonable searches and seizures. However, U.S. District Judge Sharon Johnson Coleman of the Northern District of Illinois, Eastern Division, denied both suppression motions.
During the trial proceedings, Carrazco-Martinez raised an additional challenge regarding jury instructions. He objected to an instruction that would have permitted the jury to convict him without finding that his offenses involved a specific quantity of drugs. The district court overruled this objection as well.
The jury ultimately convicted Carrazco-Martinez on both charges. He subsequently appealed to the Seventh Circuit, challenging the district court's denial of his suppression motions and its jury instruction ruling.
The three-judge panel that heard the case on December 12, 2025, included Circuit Judges Frank H. Easterbrook, Candace Jackson-Akiwumi, and John Z. Lee. Judge Lee authored the opinion affirming the lower court's decisions.
In its decision, the Seventh Circuit rejected Carrazco-Martinez's Fourth Amendment challenge to the surveillance evidence. The court found that the government's use of cell-site simulators and hidden cameras was constitutional because agents had obtained proper warrant authorization before deploying the technology.
The ruling addresses important questions about the boundaries of government surveillance in the digital age. Cell-site simulators, also known as "stingrays" or "IMSI catchers," have become increasingly common tools in federal investigations. These devices work by mimicking legitimate cell phone towers, causing nearby mobile devices to connect to them and reveal location information and other data.
The use of such technology has sparked ongoing debates about privacy rights and the scope of Fourth Amendment protections in an era of rapidly evolving surveillance capabilities. Courts across the country have grappled with when and how law enforcement can deploy these tools while respecting constitutional rights.
The Seventh Circuit's decision also upheld the district court's jury instruction regarding drug quantities. This ruling clarifies that prosecutors need not prove specific drug amounts to secure convictions under certain federal narcotics statutes, depending on how charges are structured and presented to juries.
The case highlights the challenges defendants face when challenging modern surveillance methods in court. While the Constitution requires warrants for most searches, courts have generally found that properly authorized surveillance using advanced technology does not violate Fourth Amendment protections.
The decision adds to a growing body of federal appellate precedent addressing the constitutional limits of electronic surveillance in criminal investigations. As technology continues to evolve, courts will likely face more cases testing the boundaries between effective law enforcement and individual privacy rights.
The affirmance means Carrazco-Martinez's convictions stand, and he faces sentencing under federal drug trafficking statutes. The ruling also provides guidance for future cases involving similar surveillance methods in the Seventh Circuit, which covers Illinois, Indiana, and Wisconsin.
Legal observers note that the decision reflects courts' general willingness to approve warrant-authorized surveillance, even when it involves sophisticated technology that can gather extensive personal information. The ruling underscores the importance of proper warrant procedures in validating government surveillance operations under current Fourth Amendment jurisprudence.