Similarly, with a keyword warrant, police compel the company to hand over the identities of anyone who may have searched for a specific term, such as a victims name or a particular address where a crime has occurred. Despite Molina having an alibi confirmed by multiple witnesses and the fact that the same location data impossibly placed him in multiple locations at the same time on numerous occasions, the police arrested him, locked him in jail for six days, and informed dozens of media outlets that he was the suspect in a highly publicized murder case.77. Facebook has also publicly denounced the use of geofence warrants, with a spokesperson outwardly supporting the bill. See, e.g., In re Search Warrant Application for Geofence Location Data Stored at Google Concerning an Arson Investigation (Arson), No. granting law enforcement access to thousands of innocent individuals data without a known public safety benefit.2323. Tex. . at 480. to find evidence whether by chance or other means.118118. . not due to the accompanying documents or post hoc narrowing by law enforcement or a private company.164164. There was likely no evidence of the crime in these other areas. Geofence warrants issued to federal authorities amounted to just 4% of those served on Google. In a long-awaited decision, a federal court in Virginia ruled in United States v. Chatrie that a geofence warrant violated the Fourth Amendment, but that the fruits of the unconstitutional search could nevertheless be used against the defendant under the good faith exception to the warrant requirement. 20-cv-4688 (N.D. Cal. See, e.g., How Google Handles Government Requests for User Information, Google, https://policies.google.com/terms/information-requests [https://perma.cc/HCW3-UKLX]. While Google has responded to requests for additional information at step two without a second court order, see Paul, supra note 75, this compliance does not mean the information produced is a private search unregulated by the Fourth Amendment. Carpenter v. United States, 138 S. Ct. 2206, 2213 (2018); City of Ontario v. Quon, 560 U.S. 746, 75556 (2010); Skinner v. Ry. This Note begins to fill the gap, focusing specifically on the Fourth Amendments warrant requirements: probable cause and particularity. Garrison, 480 U.S. at 84 (quoting United States v. Ross, 456 U.S. 798, 824 (1982)); see also Pharma I, No. The Chatrie opinion suggests it would approve a geofence warrant process in which a magistrate or court got to make a probable cause determination before geofence data of the likely suspect is de . Judges do not consistently engage in the informed and deliberate decisionmaking that the Fourth Amendment contemplated. . Orin S. Kerr, Searches and Seizures in a Digital World, 119 Harv. Stability Oversight Council, 865 F.3d 661, 668 (D.C. Cir. In contrast, officers are engaged in the often competitive enterprise of ferreting out crime.5353. are, in the words of Google Maps creator Brian McClendon, fishing expedition[s].103103. These searches, which occur [w]ith just the click of a button and at practically no expense,102102. See, e.g., Berger, 388 U.S. at 51 (suggesting that section 605 of the Communications Act of 1934, 47 U.S.C. If a geofence search involves looking through a private companys entire location history database step one in the Google context there are direct parallels between geofence warrants and general warrants. Selain di Jogja City Mall lantai UG Unit 38, iBox juga kini sudah hadir di Hartono Mall. After judicial approval, a geofence warrant is issued to a private company. . 2016); 1 Wayne R. LaFave, Search and Seizure: A Treatise on the Fourth Amendment 2.7(b), at 95355 (5th ed. See Ornelas v. United States, 517 U.S. 690, 700 (1996); Wong Sun v. United States, 371 U.S. 471, 480 (1963); Erica Goldberg, Getting Beyond Intuition in the Probable Cause Inquiry, 17 Lewis & Clark L. Rev. See Valentino-DeVries, supra note 25. 1241, 1245, 126076 (2010) (arguing that [t]he practice of conditioning warrants on how they are executed, id. Conclusion. the Supreme Court emphasized that the traditional rule that an officer [can] not search unauthorized areas extends to electronic surveillance.8585. Servers Controlled by Google, Inc., No. Clayton Rice, K.C. In other words, because probable cause ensures that any intrusion on privacy is justified by necessity, it considers whether there is a probability that evidence of illegal activity will be found in a specific area.149149. See Products, Google, https://about.google/products [https://perma.cc/ZVM7-G9BX]. Ninety-six percent of Americans own cell phones. First, officers had established the existence of coconspirators using traditional surveillance tools.155155. Id. But they can do even more than support legislation in one state. Google handed over the GPS coordinates and data, device data, device IDs, and time stamps for anyone at the library for a period of two hours; at the museum, for 25 minutes. New Times (Jan. 16, 2020, 9:11 AM), https://www.phoenixnewtimes.com/news/google-geofence-location-data-avondale-wrongful-arrest-molina-gaeta-11426374 [https://perma.cc/6RQD-JWYW]. and raise interesting and novel Fourth Amendment questions, they have rarely been studied.2727. See Gates, 462 U.S. at 238. Ring Road Utara, Kaliwaru, Condongcatur, Kabupaten Sleman, Daerah Istimewa Yogyakarta 55282. 5, 2021), https://www.nytimes.com/2021/03/05/us/politics/trump-proud-boys-capitol-riot.html [https://perma.cc/4CDW-LRUT]. But they can do even more than support legislation in one state. Id. L. Rev. Last . Transparency is important in understanding the scale of the risks to privacy, but there are still no clear ways to limit the use of these tools nationwide. How to Encrypt any File, Folder, or Drive on Your System, The Hunt for the Dark Webs Biggest Kingpin, Part 1: The Shadow. United States v. Lefkowitz, 285 U.S. 452, 464 (1932). The Fourth Amendment provides that warrants must particularly describ[e] the place to be searched, and the persons or things to be seized.158158. at *10. these criticisms are insufficient for the purposes of probable cause, which has never required certainty just probability. 789, 79091 (2013). This list is and will always be a work in progress and new warrants will be added periodically. Berger, 388 U.S. at 56 ([T]he indiscriminate use of such devices in law enforcement[] . . Evidence of a crime is likely available in a private companys location history database only insofar as law enforcement requests data associated with a particular time and place. Id. Because the search area was broad and thus vague, a warrant would merely invite[] the officers to roam the length of [the street]117117. Spinelli v. United States, 393 U.S. 410, 419 (1969); see also United States v. Leon, 468 U.S. 897, 914 (1984); Illinois v. Gates, 462 U.S. 213, 236 (1983); United States v. Allen, 625 F.3d 830, 840 (5th Cir. Given that particularity is inextricably tied to geographic and temporal scope, law enforcement should not be able to seek additional information about a narrowed pool of individuals without either obtaining an additional warrant or explicitly delineating this second search in the original warrant. .); United States v. Jones, 565 U.S. 400, 415 (2012) (Sotomayor, J., concurring); see also Katz v. United States, 389 U.S. 347, 360 (1967) (Harlan, J., concurring). at 48081. Simply because the government can obtain location data from private companies does not mean that it should legally be able to. See, e.g., Texas v. Brown, 460 U.S. 730, 735 (1983) (plurality opinion). 3d 648, 653 (N.D. Ill. 2019). When a geofence warrant is executed, courts should recognize that the search consists of two components: a search through (1) a private companys database for (2) data associated with a particular time and place. Geofence warrant requests in Virginia grew from 72 in 2018 to 484 in 2020, . See Google Amicus Brief, supra note 11, at 14. When law enforcement wants information associated with a particular location, rather than a particular user, it can request tower dumps download[s] of information on all the devices that connected to a particular cell site during a particular interval. Carpenter, 138 S. Ct. at 2220; see also United States v. Adkinson, 916 F.3d 605, 608 (7th Cir. Heads of Facebook, Amazon, Apple & Google Testify on Antitrust Law, C-Span, at 1:36:00 (July 29, 2020), https://www.c-span.org/video/?474236-1/heads-facebook-amazon-apple-google-testify-antitrust-law [https://perma.cc/3MFB-LNH5]. 2518(1)(c). . In Pharma I, the requested geofence spanned a 100-meter radius area within a densely populated city during several times in the early afternoon, capturing a large number of individuals visiting all sorts of amenities associated with upscale urban living.152152. vao].Vm}EA_lML/6~o,L|hYivQO"8E`S >f?o2 tfl%\* P8EQ|kt`bZTH6 sf? These reverse warrants have serious implications for civil liberties. Rooted in probability, probable cause is a flexible standard, not readily, or even usefully, reduced to a neat set of legal rules.136136. Execs. Assn, 489 U.S. 602, 61314 (1989); Camara v. Mun. The geofence warrant meant that police were asking Google for information on all the devices that were near the location of an alleged crime at the approximate time it occurred, Price explained. 19-cr-00130 (E.D. Groh v. Ramirez, 540 U.S. 551, 561 (2004). installed on 2.5 billion active devices, is more widespread than Apple's iOS. Second, this list is often quite broad. Courts have already shown great concern over technologies such as physical tracking devices,9797. The Washington Post recently published an op-ed by Megan McArdle titled "Twitter might be replaced, but not by Mastodon or other imitators." A secondary viewing method can be used via the following link: Dropbox Files. In response to two FBI requests, for example, Google produced 1,494 accounts at step two.172172. A person does notand should notsurrender all Fourth Amendment protection by venturing into the public sphere.187187. Dist. at 57. In the geofence context, the relevant consideration is the latter, and, as discussed, a geofence warrant searches two places: (1) the third partys location history records and (2) the time and geographic area delineated by the geofence warrant. BTS, Baepsae, on The Most Beautiful Moment in Life Pt. The cellphone dragnet called a geofence warrant harvests the location history generated by users of electronic devices that is stored by Google in a vast repository known as Sensorvault. See Rachel Levinson-Waldman, Hiding in Plain Sight: A Fourth Amendment Framework for Analyzing Government Surveillance in Public, 66 Emory L.J. Id. Probable cause ensures that no intrusion at all is justified without a careful prior determination of necessity130130. Because this data is highly sensitive, especially in the aggregate, a description of the things to be seized is critical to framing the scope of warrants, which judges are constitutionally tasked to review. The avid biker would do loops around his Gainesville, Fla., neighborhood and track his rides with a fitness app on his Android phone. Id. See Arson, 2020 WL 6343084, at *5. 2018); United States v. Saemisch, 371 F. Supp. 08-1332), https://www.supremecourt.gov/oral_arguments/argument_transcripts/2009/08-1332.pdf [https://perma.cc/237H-X9DN] (statement of Kennedy, J.) 20 M 392, 2020 WL 4931052, at *18 (N.D. Ill. Aug. 24, 2020). << /Filter /FlateDecode /Length 4987 >> & Poly 211, 21315 (2006). See Coolidge v. New Hampshire, 403 U.S. 443, 467 (1971) (explaining that particularity guarantees that intrusions are as limited as possible). applies to these warrants. Execs. Assn, 489 U.S. 602, 615 (1989). for Just., Cellphones, Law Enforcement, and the Right to Privacy 5 (2018), https://www.brennancenter.org/sites/default/files/2019-08/Report_Cell_Surveillance_Privacy.pdf [https://perma.cc/Z6F7-XZYV]. See, e.g., Steele v. United States, 267 U.S. 498, 50405 (1925) (concluding, despite the fact that the cases of whiskey seized may not have been the exact cases that officials saw being delivered and that served as the basis of the warrant, that particularity was satisfied). Similarly, geofence warrants in Florida leaped from 81 requests in 2018 to more than 800 last year. . without maps to visualize the expansiveness of the requested search or a list of hospitals, houses, churches, and other locations with heightened privacy interests incidentally included in the targeted area. Alfred Ng, Google Is Giving Data to Police Based on Search Keywords, Court Docs Show, CNET (Oct. 8, 2020, 4:21 PM), https://www.cnet.com/news/google-is-giving-data-to-police-based-on-search-keywords-court-docs-show [https://perma.cc/DVJ9-BWB3]. 775, 84245 (2020). Id. Sometimes, it will request additional location information associated with specific devices in order to eliminate false positives or otherwise determine whether that device is actually relevant to the investigation.7272. 19-cr-00130 (E.D. Similarly, Minneapolis police requested Google user data from anyone within the geographical region of a suspected burglary at an AutoZone store last year, two days after protests began. 20 M 525, 2020 WL 6343084, at *10 (N.D. Ill. Oct. 29, 2020); Pharma II, No. This secrecy prevents the public from knowing how judges consider these warrants and whether courts have been consistent, increasing the need for not only transparency but also uniformity in applying the Fourth Amendment to geofence warrants. Officials act with probable cause when they have reasonable belief that either an offense is being committed or evidence of a crime is available in the place searched.140140. 205, 22731 (2018); Jennifer D. Oliva, Prescription-Drug Policing: The Right to Health Information Privacy Pre- and Post-Carpenter, 69 Duke L.J. Indeed, users proactively enable location tracking,3636. Id. A coalition of more than 25 reproductive justice, civil liberties, and privacy groups are supporting the bill at introduction. In 2019, a single warrant in connection with an arson resulted in nearly 1,500 device identifiers being sent to the Bureau of Alcohol, Tobacco, Firearms, and Explosives. This type of devastating scheme ensnares victims and takes them for all theyre worthand the threat is only growing. Pharma II, No. 99, 12124 (1999). Google Amicus Brief, supra note 11, at 89. Lower courts have disagreed over whether Carpenter was a narrow decision, see, e.g., United States v. Contreras, 905 F.3d 853, 857 (5th Cir. See, e.g., Affidavit for Search Warrant at 23, United States v. Chatrie, No. In practice, inquiry into probable cause for time will likely overlap with the preliminary question of whether geofence warrants are searches. IV. But lawyers for Rhine, a Washington man accused of various federal crimes on January 6, recently filed a motion to suppress the geofence evidence. To revist this article, visit My Profile, then View saved stories. I'm sure once when I was watching the keynote on a new iOS they demonstrated that you could open up maps and draw a geofence around an area so that you could set a reminder for when you leave or enter that area without entering an address. Additionally, courts have largely recognized the ubiquity of cell phones, which are now such a pervasive and insistent part of daily life that the proverbial visitor from Mars might conclude they were an important feature of human anatomy.144144. Probable cause has always required some degree of specificity: [N]o greater invasion of privacy [should be] permitted than [is] necessary under the circumstances.114114. Stored at Premises Controlled by Google (Pharma I), No. Yet Google often responds despite not being required to by a court.7575. A sufficiently particular warrant must provide meaningful limitations on this lists length, leav[ing] the executing officer with [less] discretion as to what to seize.165165. imposes a heavier responsibility on this Court in its supervision of the fairness of procedures. (quoting Osborn v. United States, 385 U.S. 323, 329 n.7 (1966))); cf. Rather than waiting for challenges to geofence warrants to percolate and make their way up the court system,180180. We looked for any warrant described as targeting . 20 M 525, 2020 WL 6343084, at *6 (N.D. Ill. Oct. 29, 2020). See id. 27 27. On the other hand, the government has an interest in finding incriminating evidence and preventing crime.132132. . But months later, in January of this year, McCoy got an email from Google saying that his data was going to be released to local police. 2. amend. Access to the storehouse by law enforcement continues to generate controversy because these warrants vacuum the location . See Carpenter v. United States, 138 S. Ct. 2206, 2211, 2217 (2018). Location data is inextricably tied to the freedoms of speech and association. See id. Why wouldn't a more narrow setting work? After spending several thousand dollars retaining a lawyer, McCoy successfully blocked the release.44. See Arson, 2020 WL 6343084, at *8. I believe that iPhones that have Google apps like Gmail or Youtube running in the foreground have the capability to report location to Google. Berger, 388 U.S. at 57. and anyone who visits a Google-based application or website from their phone,4444. In other words, law enforcement cannot obtain its requested location data unless Google searches through the entirety of Sensorvault.7979. Jennifer Valentino-DeVries, Googles Sensorvault Is a Boon for Law Enforcement. Although the Court in Carpenter recognized the eroding divide between public and private information, it maintained that its decision was narrow and refused to abandon the third party doctrine.3838. at 117. Their support is welcome, especially since weve been calling on companies like Google, which have a lot of resources and a lot of lawyers, to do more to resist these kinds of government requests. Riley Panko, The Popularity of Google Maps: Trends in Navigation Apps in 2018, The Manifest (July 10, 2018), https://themanifest.com/mobile-apps/popularity-google-maps-trends-navigation-apps-2018 [https://perma.cc/K2HT-3RVP]. For more applicable recommendations, see Rachel Levinson-Waldman, Brennan Ctr. 14, 2018). According to Google, geofence warrant requests for the company in Virginia jumped from 72 in 2018 to 304 in 2019 and 484 in 2020. The Reverse Location Search Prohibition Act, A. 2013), vacated, 800 F.3d 559 (D.C. Cir. July 14, 2020). and that restraints on discretion are imposed by judges rather than the officers themselves.127127. by a court of competent jurisdiction.6060. See, e.g., Klayman v. Obama, 957 F. Supp. 1181 (2016). 2 (Big Hit Ent. The decision believed to be the first of its kind could make it more difficult for police to continue using an investigative technique that has exploded in popularity in recent years, privacy . Lamb, supra note 5. Now, Googles transparency report has revealed the scale at which people nationwide may have faced the same violation. Florida,1313. Geofence warrants are requested by law enforcement and signed by a judge to order companies like Google, Microsoft and Yahoo, which collect and store billions of location data points from its . . at *5 n.6. 527, 56263, 57980 (2017). A warrant that authorized one limited intrusion rather than a series or a continuous surveillance thus could not be used as a passkey to further search.8787. The warrant specifies a physical location and a time period. . at *5. First, Google and other companies may consider these requests compulsions, see Google Amicus Brief, supra note 11, at 13, perhaps because they were already required to search their entire databases, including the newly produced information, at step one, see supra p. 2515. In Wong Sun v. United States,115115. Ryan Nakashima, AP Exclusive: Google Tracks Your Movements, Like It or Not, AP News (Aug. 13, 2018), https://www.apnews.com/828aefab64d4411bac257a07c1af0ecb [https://perma.cc/2UUM-PBV6]. They also vary in the evidence that they request. Wilkes, 98 Eng. As it pertains to law enforcement, geofencing begins with officers defining an area of interest and a time period. . In the probable cause context, time should be treated as just another axis like latitude and longitude along which the scope of a warrant can be adjusted. While it is true that not everybody constantly carries their cell phone, and a cell phone is not always sending location information to Google,143143. Va. June 14, 2019). Affidavit at 1, In re Search of Info. Similarly, the Court has explained that the purpose of the particularity requirement is not limited to the prevention of general searches.125125. . That line, we think, must be not only firm but also bright. (quoting Payton v. New York, 445 U.S. 573, 590 (1980))). Geofencing is used in advanced location-based services to determine when a device being tracked is within or has exited a geographic boundary. many do not.7474. Sess. Others ask for lists of all implicated users, their phone numbers, IP addresses, and more.6666. Instead, many warrant applications provide only the latitude and longitude of the search areas boundaries.5757. The amount of behind-the-scenes cooperation between Apple-Facebook-Google-et-al and law enforcement would boggle the . Apple plans to announce ARM transition for all Macs at WWDC 2020. Search Warrant, supra note 5. Though some initial warrants provide explicitly for this extra request,7373. Carpenter, 138 S. Ct. at 2218. checking the whereabouts of millions of innocent people across the globe just to rule them in as suspects, without producing any evidence about which people, if any, were anywhere near the crime scene. Id. There is, additionally, the age-old critique that judges do not understand the technologies they confront. It turns out that these warrants are so invasive of user privacy that big tech companies like Google, Microsoft, and Yahoo are willing to support banning them. Maryland v. Garrison, 480 U.S. 79, 84 (1987). In 2017, Minnesota officers applied for a warrant asking Google for [a]ny/all user or subscriber information related to the Google searches of the names of various individuals with the first name Douglas.184184. 2012); Susan W. Brenner & Leo L. Clarke, Fourth Amendment Protection for Shared Privacy Rights in Stored Transactional Data, 14 J.L. The Richmond police used personal data from Google Maps to crack a six-month-old bank robbery, triggering protests from the suspect's counsel that the use of what is known as a "geofence warrant . See Brewster, supra note 82. The fact that geofence results indicate only proximity to a crime, not whether someone broke the law or is even suspected of wrongdoing, has also alarmed legal scholars, who worry it could enable government searches of people without real justification. Check your Apple warranty status. Katie Benner, Alan Feuer & Adam Goldman, F.B.I. Two warrants included just a commercial lot and high school event space, which was highly unlikely to be occupied.167167. serves as a useful example, especially when juxtaposed with In re Search of: Information Stored at Premises Controlled by Google, as Further Described in Attachment A (Pharma I).151151. To work, those people must be using cellphones or other electronic devices that have . In other words, officer discretion must be cabined not fully eliminated. S8183, 20192020 Leg. Companies can still resist complying with geofence warrants across the country, be much more transparent about the geofence warrants it receives, provide all affected users with notice, and give users meaningful choice and control over their private data. The "geofence" is the boundary of the area where the criminal activity occurred, and is drawn by the government using geolocation coordinates on a map attached to the warrant. In the meantime, as law enforcement relies on the warrants, countless more passersby will become collateral damage., 2023 Cond Nast. The best tool to defend that right in Email updates on news, actions, events in your area, and more. 1. iBox Service. See Google Amicus Brief, supra note 11, at 5. including Calendar, Chrome, Drive, Gmail, Maps, and YouTube, among others.4545. Take a reasonably probable hypothetical: In response to the largest set of geofence warrants revealed to date, Google provided law enforcement with the location for 1,494 devices. Arson, again, provides a good example of sufficiently particular geofence warrants. Each one of these orders could sweep in hundreds or . Probable cause for a van does not extend to a suitcase located within it,119119. . Id. Rep. at 496. on the basis that it did not specify the items and suspects to be searched, thereby giving overly broad discretion to law enforcement, a result totally subversive of the liberty of the [search] subject.9494. Ventresca, 380 U.S. at 107; Locke v. United States, 11 U.S. (7 Cranch) 339, 348 (1813). The Arson court first emphasized the small scope of the areas implicated. . There has been a dramatic increase in the use of geofence warrants by law enforcement in the U.S. Across all 50 states, geofence requests to Google increased from 941 in 2018 to 11,033 in 2020, accounting for a significant portion of all requests the company receives from law enforcement. about cell phone usage. The three stage warrant process is based on an agreement between Google and the Department of Justice's Computer Crime and Intellectual . the Court found no probable cause to search thirty blocks to identify a single laundromat where heroin was probably being sold.116116. Because it is rare to search an individual in the modern age. In the past, the greatest protections of privacy were neither constitutional nor statutory, but practical.176176. L. Rev. This understanding is consistent only with treating step one as the search.8888. Google received 982 geofence warrants in 2018, 8,396 a year later, and 11,554 in 2020, according to the latest data released by the company. 99-508, 100 Stat. Redding, 557 U.S. at 370; see also Harris, 568 U.S. at 243; Ornelas v. United States, 517 U.S. 690, 696 (1996); Brown, 460 U.S. at 742 (plurality opinion); Brinegar, 338 U.S. at 17576. The Warrant included the following photograph of the area with the geofence superimposed over it: The Warrant sought location data for every device present within the geofence from 4:20 p.m. to 5:20 p.m. on the day of the robbery. New iMac With 'iPad Pro Design Language'. Berger, 388 U.S. at 57. Through the use of geofence warrants (also known as reverse location warrants), federal and state law enforcement officers are routinely requesting that Google search users' accounts to determine who was in a certain geographic area at a particular timeand then to track individuals outside of that initially specific area and time period. First, because it has no way of knowing which accounts will produce responsive data, Google searches the entirety of Sensorvault, its location history database,6969. The Court has recognized that the reasonableness standard introduces uncertainty, see United States v. Leon, 468 U.S. 897, 914 (1984), and many have criticized the standards flexibility and have called for its further definition, see, e.g., United States v. Ventresca, 380 U.S. 102, 117 (1965) (Douglas, J., dissenting); Ronald J. Bacigal, Making the Right Gamble: The Odds on Probable Cause, 74 Miss. Going to cell phone providers is a bit tricky, thanks to the Supreme Cou Johnson, 333 U.S. at 14; see also McDonald v. United States, 335 U.S. 451, 456 (1948) (Power is a heady thing; and history shows that the police acting on their own cannot be trusted.); Lefkowitz, 285 U.S. at 464 (preferring not to rel[y] upon the caution and sagacity of petty officers while acting under the excitement that attends the capture of persons accused of crime). And that's just Google. For an overview of deference to police knowledge, see generally Anna Lvovsky, The Judicial Presumption of Police Expertise, 130 Harv. Illinois v. Gates, 462 U.S. 213, 232 (1983); see also Florida v. Harris, 568 U.S. 237, 244 (2013); Maryland v. Pringle, 540 U.S. 366, 371 (2003). As a result, and because Google has recently revealed how it processes these warrants, this Note discusses Google in particular detail, though it functions as a stand-in for any company that collects and stores location data. Jake Laperruque, Project on Government Oversight, Torn between the latest phones? But lawyers for Rhine, a Washington man accused of various federal crimes on January 6, recently filed a motion to . Id. Google Amicus Brief, supra note 11, at 13. Namun tidak seperti beberapa . See, e.g., Pharma I, No. See, e.g., Elm, supra note 27, at 11, 13. Geofence warrants are warrants used by police to tech companies for information about devices in specific areas. 1995 (2017). Steagald v. United States, 451 U.S. 204, 220 (1981). North Carolina,1717. xKGr) ]c .`;#JV~GfF"F6xfedmBF{-ym7i}g/b}hjnWow8Y"av4J?wm_5_/xq .); Google Amicus Brief, supra note 11, at 14 (To produce a particular users CSLI, a cellular provider must search its records only for information concerning that particular users mobile device.). In subsequent decisions, the Court reinforced the notion that probable cause for a single physical location cannot be widely extended to nearby places.