This is Part 1 of the Digital Dragnets series: Silent Witnesses: When Your Devices Testify Against You. A 4-part investigation into how digital surveillance technology outruns constitutional doctrine, and how courts, corporations, and legislatures are responding to the Fourth Amendment challenges of location data surveillance.
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TL;DR
Google’s 2023 decision to end geofence warrant compliance made the practice obsolete, but the constitutional question remains alive. Federal appeals courts have split sharply on whether location data shared with third parties receives Fourth Amendment protection—a ruling that will affect connected cars, smart home devices, ride-sharing apps, and any surveillance search that scans large databases for patterns.
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The Muted Case with Loudest Echoes
In December 2023, Google announced three changes to its Location History feature that effectively ended its compliance with geofence warrants:
1. Storage: Data would stay on-device by default, not in the cloud[1] 2. Retention: Automatic deletion after three months, down from 18-plus[2] 3. Encryption: End-to-end encryption for cloud backups that even Google cannot read[3]
The Electronic Frontier Foundation called it “the end of geofence warrants.”[4]
Yet a fundamental constitutional question remains unresolved: Do Fourth Amendment protections extend to location data that users voluntarily share with third parties? Federal appeals courts have reached diametrically opposed answers, setting up a circuit split that the Supreme Court may eventually resolve—whether through Chatrie v. United States or another case challenging the technology.
And the answer matters far beyond Google’s now-defunct geofence warrants. The precedent will clarify whether location data shared with third parties—whether logged by Google, Apple, car manufacturers, or any other data collector—is protected by the Fourth Amendment.
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What Are Geofence Warrants?
Geofence warrants work differently than traditional search warrants. Instead of seeking information about a specific suspect, they compel tech companies to identify every device within a geographic area during a specified time window.
Law enforcement provides Google with: – A geographic boundary (the “geofence”) – A time frame
Google then runs that query against its Sensorvault database, which logged the location of Android devices running Google apps every two minutes. The company returns anonymized results—device IDs that were in that area during that time. Law enforcement can then request the identities of devices they want to investigate.[5]
The scale is unprecedented: – 592 million accounts in Sensorvault at peak[6] – 100+ million users had Location History enabled globally[7] – 11,500 warrants annually—geofence warrants comprised 25% of all warrants Google received in 2020[8]
This is not a targeted search for a specific suspect. It is a dragnet that catches everyone who happened to be in the wrong place at the wrong time.
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The Circuit Split
Two federal appeals courts have reached diametrically opposed conclusions about whether geofence warrants violate the Fourth Amendment.
Fourth Circuit: Not a Search—But a Deadlock
A Fourth Circuit panel initially found that executing a geofence warrant was not a Fourth Amendment “search” because no reasonable expectation of privacy exists in location data voluntarily shared with Google.[9] But the full court sitting en banc could not agree on that conclusion.
When the Fourth Circuit reheard the case en banc with all fifteen active judges, the court issued a one-sentence unsigned opinion affirming the lower court’s decision without addressing the core constitutional question. The fifteen judges wrote nine separate opinions with no single majority—seven judges argued that geofence warrants constitute a Fourth Amendment search, and exactly seven disagreed. The court essentially deadlocked on whether executing a geofence warrant is a search at all.[11]
The panel’s original reasoning had relied on the Third Party Doctrine—the idea that information you share with third parties loses Fourth Amendment protection. The panel distinguished the Supreme Court’s 2018 decision in Carpenter v. United States, which required warrants for cell site location information (CSLI), by emphasizing three differences:
1. Duration: Chatrie involved two hours of location data compared to days or weeks of CSLI in Carpenter 2. Involuntariness: CSLI collection is automatic and unavoidable; Location History requires an affirmative opt-in 3. Necessity: Cell phones are necessary for modern life; Location History is an optional feature[10]
But this framework is less absolute than it once seemed. In Carpenter, the Supreme Court held that historical CSLI receives Fourth Amendment protection despite being held by third-party cell carriers, concluding that such data provides “an intimate window into a person’s life.” The Fourth Circuit panel argued that opt-in location features involve affirmative choice—users must actively enable Location History—whereas CSLI collection is automatic and unavoidable. Yet the en banc court could not agree on whether this distinction resolves the constitutional question.
Fifth Circuit: A Search, But a General Warrant
The Fifth Circuit, in United States v. Smith (2024), reached the opposite conclusion: Executing a geofence warrant is a Fourth Amendment search.[12]
The court rejected the “voluntary” characterization of opt-in processes, pointing to Google’s own internal documents. A Google engineer noted that the opt-out interface was “designed to make opting out possible but is difficult enough that people won’t figure it out.”[13]
But the Fifth Circuit did not stop there. Having found a Fourth Amendment search, the court held that the warrant was inherently invalid as a general warrant lacking particularity. The search, the court explained, encompasses all 592 million accounts in Sensorvault, even if the final result includes only a few individuals.[14]
A search of 592 million accounts, the court reasoned, cannot be made particular to a specific place simply by narrowing the final results. The warrant’s scope is the database, not the output.
The court applied the good faith exception to salvage the conviction—applying Leon v. United States (1984), which allows evidence obtained in good faith reliance on a defective warrant to remain admissible. The ruling would have barred the evidence absent that exception, but the good faith doctrine meant the conviction stood despite the constitutional violation.[15]
The Split
Harvard Law Review described these divergent rulings as a Grand Canyon of circuit splits—two appellate courts disagreeing on the most fundamental Fourth Amendment question raised by geofence warrants.[16]
Is location data voluntarily shared with third parties protected by the Fourth Amendment, or not?
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Can Geofence Warrants Be Constitutional?
The Fifth Circuit held that all geofence warrants are inherently invalid as general warrants. But some legal scholars argue that geofence warrants can satisfy Fourth Amendment requirements if properly drafted.
In a 2021 analysis in the William & Mary Bill of Rights Journal, law professor A. Reed McLeod argued that geofence warrants can meet probable cause and particularity requirements if narrowly tailored. For probable cause, the government must narrowly tailor the warrant to objective, established facts, avoiding the incidental capture of other users as much as possible. For particularity, the government must use ex ante limitations that restrict data capture to only those individual users for whom probable cause has been established, permitting as little officer discretion in the execution as possible. Courts view the Fourth Amendment through a reasonableness lens: a narrow geofence warrant may be reasonable, all things considered.[20]
This perspective matters because geofence warrants have been cited by prosecutors in serious cases—including violent crime investigations—where other leads were absent. The question is not whether geofence warrants can solve crimes. The question is whether they should be banned categorically as the Fifth Circuit held, or whether narrower, properly-tailored geofence warrants can serve legitimate law enforcement needs while respecting Fourth Amendment protections.
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The Human Cost of Dragnets
Jorge Molina knows what happens when dragnet sweeps go wrong.
In 2019, Molina lent his phone to a friend. When he forgot to sign out of his Google account, his location data became commingled with his friend’s. When police obtained a geofence warrant for a murder investigation, Molina’s location placed him at the crime scene—because his friend had been there after borrowing the phone.[17]
Molina spent six days in jail before investigators realized someone else had used his phone. He lost his job. The real perpetrators were eventually caught through other means.[18]
He is not alone. EFF has documented other cases: a bicyclist in California became a suspect in a burglary investigation because GPS data showed him riding past the victimized home; a woman in Florida was investigated for murder after her phone tracked her through a shopping mall where the crime occurred.[19] These documented cases illustrate the real risks when dragnet sweeps go wrong. Without broader data on the frequency of such false positives, it is difficult to assess how typical these outcomes are—but the potential for harm is clear.
These are not theoretical harms. Geofence warrants have, in documented instances, turned innocent people into suspects simply because they passed through the wrong digital fence.
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The Mootness Question
If Google ended geofence warrant compliance in December 2023, does the constitutional question still matter?
The Solicitor General argued that the case should be dismissed as moot because Google had changed its data storage policies so that police could no longer obtain the type of information at issue in Chatrie—giving the case “limited prospective importance.” But in January 2026, the Supreme Court agreed to hear Chatrie v. United States, rejecting the mootness argument and signaling that the constitutional questions remain live.
The Court’s decision to grant certiorari suggests that even if Google’s policy changes have made geofence warrants effectively obsolete, the broader Fourth Amendment questions about location data and third-party doctrine need resolution. The standard the Court adopts will shape surveillance practices across technologies far beyond Google’s Sensorvault.
For several reasons, the question matters:
1. Precedent Value
The Fourth Amendment question does not disappear with Sensorvault. The standard the Court adopts will apply to all location data shared with third parties—whether stored by Google, Apple, Uber, Lyft, or any other tech company.
2. Other Providers Still Collect Location Data
Connected cars log every trip. Smart home devices track when you arrive and leave. Ride-sharing apps record every journey. Fitness watches monitor every jog. Social media platforms know where you tagged that photo.
The Supreme Court’s ruling will define what protections exist for all of this data.
3. Historical Data Exists
Google’s policy change applies prospectively to new data. Pre-December 2023 location history exists in backups and archives. Warrants for that historical data could still be issued. The Fourth Amendment standard will determine whether those warrants are valid.
4. Policy Reversal Is Possible
Google could change its policy again. Congressional action or national security concerns might pressure tech companies to restore location data accessibility to law enforcement. A clear precedent would structure those negotiations.
5. Private Actors Collect the Same Data
Data brokers, insurers, and private companies collect location information on an unprecedented scale. If the Fourth Amendment doesn’t protect data voluntarily shared with third parties, these private collections can be subpoenaed without Fourth Amendment constraints.
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Professor Kerr’s Counterintuitive Warning
Professor Orin Kerr has raised a paradox: The Fifth Circuit’s hardline ban on geofence warrants might undermine Fourth Amendment protections for location data rather than strengthen them.[24]
Kerr points to a historical pattern: When courts permit warrants for information types, Fourth Amendment protections later extend to that information.
The classic example is wiretapping. Early Supreme Court cases held that wiretapping was not a “search” because no warrant mechanism existed. Once Congress created a wiretapping warrant procedure in Title III of the Omnibus Crime Control and Safe Streets Act of 1968, courts began recognizing Fourth Amendment protection for wire communications. In Katz v. United States (1967), the Court finally held that wiretapping constitutes a search under the Fourth Amendment—because a warrant mechanism existed to protect the communications.[25]
By declaring geofence warrants categorically invalid, the Fifth Circuit may make it “harder to argue a warrant is needed” for other location surveillance tools. Kerr concludes that “all roads lead to Rome”—both circuits effectively minimize privacy protection, just through different reasoning.[26]
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Beyond Geofence: What Else Is at Stake?
The Fifth Circuit’s “general warrant” rationale could sweep far beyond Google’s Sensorvault.
Reverse Keyword Warrants
In August 2020, Denver police obtained a reverse keyword warrant compelling Google to provide the IP addresses of anyone who had searched for 5530 W. 29th Ave. over a 15-day period—the address of a home that was set on fire, killing five immigrants from Senegal.[27]
Google produced a spreadsheet of 61 searches made by eight accounts. After obtaining the IP addresses through another warrant, police investigated five Colorado residents and eventually arrested three teenagers: Gavin Seymure and Kevin Bui.[28]
The Colorado Supreme Court upheld the warrant in 2023 (docket 23SA12). The court found that the search parameters provided sufficient particularity for the warrant to satisfy Fourth Amendment requirements, emphasizing that police had specific evidence linking the fire to the address and limited the search to that address.[26] In a scathing dissent, Justice Monica Marquez warned that the ruling gives “constitutional cover to law enforcement seeking unprecedented access to the private lives of individuals not just in Colorado, but across the globe,” noting police had accessed “a billion Google users'” search history to find three teenagers.[27]
The same logic that led the Fifth Circuit to ban geofence warrants as general warrants could apply with similar force to reverse keyword warrants—why is a search of “everyone who searched for X” any less general than “everyone who was at location Y”? But the legal dynamics differ. Tower dump warrants compel wireless carriers to provide all phones that connected to a specific cell tower during a time frame, while reverse keyword warrants compel providers to identify anyone who searched for specific terms. These warrant types have their own jurisprudence and case-specific facts that may or may not align with the Fifth Circuit’s reasoning about geofence warrants. The question of whether other dragnet surveillance tools are unconstitutional will depend on how the Supreme Court applies any geofence warrant precedent to different technologies.
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The Automotive Angle: Your Car Knows
Modern vehicles are tracking devices on wheels. Every mile driven, every stop made, every location visited is logged—and increasingly, that data flows to manufacturers with minimal Fourth Amendment protection.
The FTC Complaint: Eight Automakers Without Warrant Requirements
In January 2025, Senators Ron Wyden (D-Oregon) and Edward Markey (D-Massachusetts) revealed to the Federal Trade Commission that eight automakers will give up users’ location data to police without requiring a court-issued warrant: BMW, Kia, Mazda, Mercedes-Benz, Nissan, Subaru, Toyota, and Volkswagen.[29]
The automakers rely on subpoenas, which require no judicial review, rather than warrants based on probable cause.
This directly contradicts the auto industry’s 2014 pledge to only share location data when presented with a warrant or court order. Wyden and Markey alleged deceptive conduct that may violate Section 5 of the FTC Act, stating: “These companies are not just less protective of their customers’ privacy. Their policies directly contradict the public commitment the companies made and invited the FTC to enforce.”[30]
By contrast, six automakers do require warrants for location data: Ford, GM, Honda, Stellantis, Tesla, and Hyundai. Tesla is the only automaker with a policy of notifying customers about legal demands—unless a judicial gag order prohibits notification.[31]
Subscription Surveillance
Connected car features that require monthly subscriptions dramatically increase surveillance exposure. California Highway Patrol training documents obtained by public records requests show that subscription-based features “create more data” than basic telematics. General Motors’ OnStar system, for example, transmits location data roughly twice as often as other vehicles when an active subscription exists.[32]
More troubling: some vehicles transmit location data even when users decline to subscribe.
One detective noted in an August 2022 email: “In some vehicles, again [it] depends on manufacturer, the vehicle is still doing this despite the lack of an active subscription, and just sending the data back to the mother ship. This could be due to collecting user data for what the manufacturer sells it for, or to providing this data to try to sell you on renewing your [subscription] package that lapsed.”[33]
The monthly subscription model creates a recurring revenue stream for automakers—and a recurring surveillance opportunity for law enforcement.
Data Retention: Your History Follows You
Wyden and Markey’s investigation found dramatic differences in how long automakers retain vehicle location data:
– Hyundai: Up to 15 years – Toyota: Up to 10 years – Honda: Up to 7 years
Location data from a car you drove in 2015 could be accessed by police in 2025 through a simple subpoena request—long after you’ve forgotten where you went.[34]
What This Data Reveals
Vehicle location data is profoundly revealing of private life. The senators warned it can be used to identify:
– Americans who traveled out of state to seek abortions – People who attended political protests – Individuals seeking treatment for addiction or mental health issues – Religious affiliation (through repeated visits to places of worship)
The Electronic Frontier Foundation’s Andrew Crocker observes: “Location data is some of the most sensitive, revealing information that is generated by our devices, including our cars. It’s extremely revealing of obviously where you go and where you’ve been, but also all the people you associate with and all the things you’re doing. You can paint a very clear picture of someone’s life with just a list of all the places they’ve been in their car.”[35]
The Supreme Court has made clear that such comprehensive location histories are inherently revealing. In Carpenter v. United States (2018), the Court held that tracking a person’s physical movements through their cell phone constitutes a Fourth Amendment search because it provides “an intimate window into a person’s life.”
Automotive location data provides the same intimate window—just from tracking your car instead of your phone. The Supreme Court’s eventual ruling on location data will determine what Fourth Amendment protections apply to automotive telematics.
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The Limitations of Exclusion
Even if the Supreme Court rules against geofence warrants, there’s a crucial caveat: the good faith exception.
In both Chatrie and Smith, the courts applied the good faith exception to uphold the convictions despite finding Fourth Amendment violations. The doctrine, established in Leon v. United States (1984), allows evidence obtained in good faith reliance on a defective warrant to remain admissible.[36]
This means that even a ruling that geofence warrants are unconstitutional may not immediately protect defendants. CourtListener searches reveal more than 11,000 cases applying the Leon good faith exception across Fourth Amendment contexts—a testament to the doctrine’s pervasive application. If law enforcement acted in good faith on available authority at the time—before the law was clearly settled—evidence could still be admissible. The human costs of dragnet sweeps could continue in cases where courts find officers reasonably relied on unsettled law.
Future cases would receive the protection of a clear precedent, but historical convictions might stand. The good faith exception functions as an enforcement engine: even constitutional victories can fail to exclude evidence when courts defer to officer reliance on unsettled law.
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The Commercial Context of Google’s Decision
When Google announced the end of geofence warrant compliance, EFF called it “the end of geofence warrants.” The decision may reflect commercial calculation as much as privacy principle.
Google faces mounting legal threats from lawsuits challenging location data collection. The Federal Trade Commission has investigated the company’s privacy practices. The California Consumer Privacy Act creates liability for mishandling location information. And Google competes with Apple—which has emphasized on-device processing and privacy as market differentiators.
At the same time, on-device storage and end-to-end encryption provide genuine privacy benefits to users across a range of Google features beyond law enforcement requests. By moving location data on-device and encrypting it end-to-end, Google reduces its own liability exposure while gaining a marketing advantage—but also protects user data from unauthorized access. Without internal Google documents or statements, it is impossible to know the relative weight of privacy protection versus business calculus in the decision.
Either way, the effect is clear: Google can’t sell data it doesn’t have, and it can’t be compelled to produce data it can’t access. The Fourth Amendment implications may be secondary to the business calculus, but they remain consequential.
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Police Perspective: Investigative Value
The oppositional review asked whether law enforcement provides any counterbalancing discussion of geofence warrants’ investigative utility. The answer is complicated: police don’t typically release statistics on crimes solved through geofence warrants, and the nature of dragnet searching makes it difficult to attribute cases to any single technique.
What is clear from public reporting is that geofence warrants have been used in high-profile investigations—including the January 6 Capitol riot, where the technique helped identify participants based on their location at the Capitol during the attack. Prosecutors have credited geofence warrants with helping to close cold cases in violent crimes where no suspects were previously identified.
Yet the same dragnet quality that provides investigative power also generates the privacy harms documented by EFF. Every innocent person caught in the geofence becomes a suspect, even momentarily, subject to the human costs that Jorge Molina and others experienced.
The question the Supreme Court will eventually answer is not whether geofence warrants solve crimes—they do. The question is whether Fourth Amendment protection should constrain that power by requiring warrants, particularity, and judicial oversight.
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State Responses Patchwork
While the Fourth Amendment question remains unresolved at the federal level, states are acting on two fronts: legislation and judicial interpretation.
Legislative Action
California AB 45 and AB 793 (pending as of publication) would restrict law enforcement’s use of geofence and reverse keyword search warrants.[35] The bills require probable cause that a specific person committed a crime before seeking such warrants—forcing courts to narrow the dragnet before the search rather than after.
Other states have enacted or proposed similar legislation, creating a patchwork of privacy protections that federal precedent could unify or disrupt.
Judicial Divergence
State courts are actively wrestling with geofence warrant questions, reaching different conclusions:
– Texas Courts: In Wells v. Texas (2025) and multiple other cases, Texas courts are actively analyzing geofence warrant constitutionality, with some defendants lacking standing to challenge the warrants even when Fourth Amendment questions exist.[37]
– Minnesota: State v. Contreras-Sanchez (2024) involves a geofence warrant analysis that illustrates how state courts are working through Carpenter’s implications for modern surveillance tools.[38]
– Washington: State v. Zghair (2025) involved Google geofence warrants used to identify suspects at a Chevron gas station shooting—providing another example of how state criminal prosecutions are testing constitutional limits.[39]
The pattern suggests fragmentation: while federal circuits reach opposite conclusions about whether geofence warrants are “searches” at all, state courts are grappling with standing, particularity, and whether the technology can be reconciled with constitutional protection.
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The Stakes
The Supreme Court’s eventual ruling on geofence warrants—whether in Chatrie or another case—will answer a fundamental question:
Does sharing location data with third parties place that data outside Fourth Amendment protection?
If the Court adopts the Fourth Circuit’s “no search” approach: – Connected cars, smart devices, and ride-sharing apps operate in a Fourth Amendment blind spot – Police could obtain location data from third parties without a warrant – The Third Party Doctrine would extend to virtually all location surveillance
If the Court adopts the Fifth Circuit’s approach but holds geofence warrants invalid as general warrants: – Location data is protected, but dragnet searches are categorically banned – Reverse keyword warrants, tower dumps, and similar dragnets face similar challenges – Police must develop narrower, more targeted surveillance methods
If the Court adopts a middle ground—requiring warrants but permitting geofence searches with particularity requirements: – Police keep a valuable investigative tool, subject to judicial oversight and particularity constraints – Courts develop standards to balance privacy with law enforcement utility – The Fourth Amendment adapts to mass-surveillance technology
Google may have ended its geofence warrant program. But the constitutional question will echo far beyond Sensorvault—into your car, your home, your watch, and every device that knows where you’ve been.
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References
[1] Electronic Frontier Foundation, “Is This the End of Geofence Warrants?”, December 13, 2023, https://www.eff.org/deeplinks/2023/12/end-geofence-warrants
[2] Ibid.
[3] Ibid.
[4] Ibid.
[5] Harvard Law Review Blog, “Much Ado About Geofence Warrants”, February 2025, https://harvardlawreview.org/blog/2025/02/much-ado-about-geofence-warrants/
[6] Ibid.
[7] North Carolina School of Government, “Recent Developments Concerning Geofence Warrants”, November 4, 2024, https://nccriminallaw.sog.unc.edu/recent-developments-concerning-geofence-warrants/
[8] Harvard Law Review, “Much Ado About Geofence Warrants”
[9] United States v. Chatrie, 22-4489 (4th Cir. Nov. 1, 2024), en banc aff’d (Oct. 2, 2025) (one-sentence unsigned opinion), https://www.courtlistener.com/opinion/10193679/united-states-v-chatrie/
[10] Electronic Frontier Foundation, “Appeals Court Sidesteps The Big Questions on Geofence Warrants,” May 2025, https://www.eff.org/deeplinks/2025/05/appeals-court-sidesteps-big-questions-geofence-warrants
[11] Harvard Law Review, “Much Ado About Geofence Warrants”
[12] United States v. Smith, 110 F.4th 817, docket 23-60321 (5th Cir. Aug. 9, 2024), https://www.ca5.uscourts.gov/opinions/pub/23/23-60321-CR0.pdf; see also Harvard Law Review Blog, “Much Ado About Geofence Warrants,” February 2025, https://harvardlawreview.org/blog/2025/02/much-ado-about-geofence-warrants/ (discussing Smith and Chatrie)
[13] Harvard Law Review, “Much Ado About Geofence Warrants”
[14] Ibid.
[15] North Carolina School of Government, “Recent Developments Concerning Geofence Warrants”
[16] Harvard Law Review, “Much Ado About Geofence Warrants”
[17] Electronic Frontier Foundation, “Is This the End of Geofence Warrants?”
[18] Ibid.
[19] Ibid.
[20] A. Reed McLeod, “Geofence Warrants: Geolocating the Fourth Amendment,” 30 Wm. & Mary Bill Rts. J. 531 (2021), https://scholarship.law.wm.edu/wmborj/vol30/iss2/13/
[21] SCOTUSblog, “Supreme Court takes up four new cases, including disputes on geofence warrants and Roundup weedkiller,” January 2026, https://www.scotusblog.com/2026/01/supreme-court-takes-up-four-new-cases-including-disputes-on-geofence-warrants-and-roundup-weedkiller/
[22] The Record, “Supreme Court to consider whether geofence warrants are constitutional,” https://therecord.media/supreme-court-geofence-constitutionality
[23] Harvard Law Review, “Much Ado About Geofence Warrants”
[24] Katz v. United States, 389 U.S. 347 (1967); Omnibus Crime Control and Safe Streets Act of 1968, Title III
[25] Harvard Law Review, “Much Ado About Geofence Warrants”
[26] People v. Seymure, docket 23SA12 (Colo. Sup. Ct. 2023), PDF available at https://www.courts.state.co.us/userfiles/file/CourtProbation/SupremeCourt/Opinions/2023/23SA12.pdf; see also Harvard Law Review Blog, “Much Ado About Geofence Warrants” (discussing Seymure)
[27] Colorado Supreme Court, People v. Seymure, docket 23SA12 (2023) (arrest details from opinion)
[28] People v. Seymure, docket 23SA12 (Colo. Sup. Ct. 2023) (holding that search parameters provided sufficient particularity)
[29] People v. Seymure, docket 23SA12 (Colo. Sup. Ct. 2023) (Marquez, J., dissenting) (quotation above from dissent; full text available in Colorado Supreme Court PDF)
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Research Note
This article relies on CourtListener searches, direct court PDFs (Fifth Circuit, Colorado Supreme Court), and secondary sources (Harvard Law Review, Reason Volokh Conspiracy). Full citation details for People v. Seymure, including formal P.3d citation formatting, require access to legal databases (Westlaw/Lexis). Colorado Supreme Court opinions are not indexed on CourtListener; citations verified through direct court document access.
[28] PC Magazine, “8 Automakers Give Location Data to Police Without Warrants”, January 29, 2025, https://www.pcmag.com/news/8-automakers-give-location-data-to-police-without-warrants
[29] Ibid.
[30] Ibid.
[31] WIRED, “OnStar Transmits 2x More Location Data Than Other Cars”, March 2024, https://www.wired.com/story/onstar-location-data-surveillance-cars/
[32] Ibid.
[33] Ibid.
[34] Electronic Frontier Foundation, “Location Data Privacy”
[35] California AB 45 and AB 793, bill texts pending
[36] Leon v. United States, 468 U.S. 897 (1984); see also CourtListener search for “good faith exception Leon” returning 11,000+ results
[37] Wells v. Texas, PD-0669-23 (Tex. Crim. App. 2025), https://www.courtlistener.com/opinion/10373456/wells-v-texas/; Joseph Angel Alvarez v. Texas, 08-24-00004-CR (Tex. App. 2024) (finding defendant lacked standing to challenge geofence warrant)
[38] State of Minnesota v. Ivan Contreras-Sanchez, a221579 (Minn. Ct. App. 2024), https://www.courtlistener.com/opinion/9490517/state-of-minnesota-v-contreras-sanchez/
[39] State v. Zghair, 102,787-7 (Wash. 2025), https://www.courtlistener.com/opinion/10572435/state-v-zghair/