apple geofence warrant

Judicial involvement in the warrant process has long been justified on the basis that judges are neutral and detached5151. Carpenter, 138 S. Ct. at 221920. After producing a narrowed list of accounts in response to a warrant, companies often engage in a back-and-forth with law enforcement, where officials requestadditional location information about specific devices from before or after the requested timeframe to narrow the list of suspects.8282. Google now gets geofence warrants from agencies in all 50 states, Washington, D.C., and the federal government. not due to the accompanying documents or post hoc narrowing by law enforcement or a private company.164164. Lab. 2020); State v. Tate, 849 N.W.2d 798, 813 (Wis. 2014) (Abrahamson, C.J., dissenting). at *1. and the Supreme Court has maintained that warrants are generally preferred.3030. Because the search area was broad and thus vague, a warrant would merely invite[] the officers to roam the length of [the street]117117. In 2018, Google received 982 geofence warrants from law enforcement; in 2020 that number surged to 11,554, according to the most recent data provided by the company. A geofence warrant is a type of search warrant that law enforcement typically use when they do not have a suspect. As consumers turn over ever-increasing information to third parties as part of engaging in daily life, there have been vigorous criticisms of the doctrine as out of touch with the modern era and calls to amend it or even abolish it entirely. Geofence Warrants On The Rise. Jake Laperruque, Project on Government Oversight, Torn between the latest phones? The overwhelming majority of the warrants were issued by courts to state and local law enforcement. WIRED may earn a portion of sales from products that are purchased through our site as part of our Affiliate Partnerships with retailers. . Surveillance Applications & Ords., 964 F.3d 1121, 1129 (D.C. Cir. L.J. 13, 2019), https://www.nytimes.com/interactive/2019/04/13/us/google-location-tracking-police.html [https://perma.cc/3RF9-6QG6]. Geofence warrants are warrants used by police to tech companies for information about devices in specific areas. New York,1616. Just., Summer 2020, at 7. In order for step twos back-and-forth to be lawful, therefore, the geofence warrant must have authorized these further searches. These reverse warrants have serious implications for civil liberties. 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. Id. The same principle should apply to geofence warrants. See Berger v. New York, 388 U.S. 41, 56 (1967). zS For a discussion of the Carpenter Courts treatment of the third party doctrine, see Laura K. Donohue, Functional Equivalence and Residual Rights Post-Carpenter: Framing a Test Consistent with Precedent and Original Meaning, 2018 Sup. 2017). First, the narrowness of the anonymized list is largely in the hands of private companies, rather than the judiciary or legislature, which is impracticable in the long run. When law enforcement seeks CSLI associated with a particular device, it merely asks for information that phone companies already collect, compile, and store.7878. 8$6m7]?{`p|}IZ%pVcn!9c69?+9T:lDhs%fFfA# a$@-qyKmE3 /6"E3J3Lk;Np. Id. 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). 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. Additionally, geofence warrants are usually sealed by judges.5858. Rep. 807 (KB); and Money v. Leach (1765) 97 Eng. . See, e.g., Texas v. Brown, 460 U.S. 730, 735 (1983) (plurality opinion). Google Amicus Brief, supra note 11, at 13. Instead, with geofence warrants, they draw a box on a map, and compel the company to identify every digital device within that drawn boundary during a given time period. One such feature is Apple's proposed child sexual abuse material detection (CSAM . [T]he liberty of every [person] would be placed in the hands of every petty officer.9090. Geofence and reverse keyword warrants completely circumvent the limits set by the Fourth Amendment. 1995 (2017). Last week, Google responded to calls by a civil liberties coalition, including POGO, to issue a report of how often it receives geofence demands. Berger, 388 U.S. at 56 ([T]he indiscriminate use of such devices in law enforcement[] . First, officers had established the existence of coconspirators using traditional surveillance tools.155155. Though some initial warrants provide explicitly for this extra request,7373. Theres always collateral damage, says Jake Laperruque, senior policy counsel for the Constitution Project at the nonprofit Project on Government Oversight. Apple, whose software runs mobile devices such as its iPhone, cannot respond to geofence warrants, a company spokesperson said. Cops have discovered Google houses plenty of location data. Rep. 1075 (KB). Rather than waiting for challenges to geofence warrants to percolate and make their way up the court system,180180. S8183, 20192020 Leg. Android controls around eighty-five percent of the global smartphone market. 591, 619 (2016) (explaining that probable cause requires the government to show a likely benefit that justifies [the searchs] cost). Each one of these orders could sweep in hundreds or . vao].Vm}EA_lML/6~o,L|hYivQO"8E`S >f?o2 tfl%\* P8EQ|kt`bZTH6 sf? and balances two competing interests. In response, law enforcement may argue that it has historically been allowed to examine[] [papers], at least cursorily, in order to determine whether they are, in fact, among those papers authorized to be seized. Andresen v. Maryland, 427 U.S. 463, 482 n.11 (1976); see also United States v. Evers, 669 F.3d 645, 652 (6th Cir. Animal rights activists have captured the first hidden-camera video from inside a carbon dioxide stunning chamber in a US meatpacking plant. In keeping with Google's established approach, the Geofence Warrant described a three-step process by which law . Here, where the government compelled the initial search and directs the step two inquiry, it would be improper to describe the private company as anything other than an agent or instrument of the Government. Id. Specific legislative solutions are beyond the scope of this Note. ([Such awareness] may alter the relationship between citizen and government in a way that is inimical to democratic society. (quoting United States v. Cuevas-Perez, 640 F.3d 272, 285 (7th Cir. 775, 84245 (2020). PLGB9hJKZ]Xij{5 'mGIP(/h(&!Vy|[YUd9_FcLAPQG{9op QhW) 6@Ap&QF]7>B3?T5EeYmEc9(mHt[eg\ruwqIidJ?"KADwf7}BG&1f87B(6Or/5_RPcQY o/YSR0210H!mE>N@KM=Pl 1, 2021), https://www.statista.com/statistics/232786/forecast-of-andrioid-users-in-the-us [https://perma.cc/4EDN-MRUN]. To leave probable cause determinations to officers would reduce the [Fourth] Amendment to a nullity and leave the peoples homes secure only in the discretion of police officers.5454. It is unclear whether the data collected is stored indefinitely, see Webster, supra note 5 (suggesting that it is), but there are strong constitutional arguments that it should not be, see United States v. Ganias, 824 F.3d 199, 21518 (2d Cir. 347, 37388. The Court has recognized that when these rights are at issue, the warrant requirements must be accorded the most scrupulous exactitude. Stanford v. Texas, 379 U.S. 476, 485 (1965); see id. how can probable cause to search a store located in a seventy-story skyscraper possibly extend to all the other places in the building? at 221718; Jones, 565 U.S. at 429 (Alito, J., concurring); id. See Gates, 462 U.S. at 238. Berger v. New York, 388 U.S. 41, 62 (1967); see also Lopez v. United States, 373 U.S. 427, 464 (1963) (Brennan, J., dissenting). 99, 12124 (1999). Apple plans to announce ARM transition for all Macs at WWDC 2020. Maine,1414. It also means that with one document, companies would be compelled to turn over identifying information on every phone that appeared in the vicinity of a protest, as happened in Kenosha, Wisconsin during a protest against police violence. Since then, it has generally been understood that no warrant can authorize the search of everything or everyone in sight.9696. at 1245, is constitutionally suspect). If a geofence warrant is a search, it is difficult to understand why the searchs scope is limited to step two and does not include step one. After pressure from activists, Google revealed in a press release last week that it had granted geofence warrants to U.S. police over 20,000 times in the past three years. Law enforcement has served geofence warrants to Google since 2016, but the company has detailed for the first time exactly how many it receives. Surveillance footage showed that the perpetrator held a cell phone to his ear before he entered the bank. 1. A warrant requesting accounts located within the geographical area bordered to the north at 26.947300, -80.357595, to the east at 26.94672, -80.356715, to the south at 26.946227, -80.357316, and to the west at 26.946762, -80.358073, for example, does not illustrate the scope of the requested search. It is clear that technology will only continue to evolve. It is the essential source of information and ideas that make sense of a world in constant transformation. New iMac With 'iPad Pro Design Language'. it is reasonable to believe that the perpetrators phone data can be found in these records. Geofence warrants issued to federal authorities amounted to just 4% of those served on Google. Time and Place. The New York bill is still far from passage and impacts just one state. 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 . Google received more than 20,000 geofence warrants in the US in the last three calendar years, making up more than a quarter of all warrants the tech giant received in that time . Groh v. Ramirez, 540 U.S. 551, 561 (2004). Jennifer Valentino-DeVries, Googles Sensorvault Is a Boon for Law Enforcement. In response to two FBI requests, for example, Google produced 1,494 accounts at step two.172172. With respect to eavesdropping technology, the Court in Berger noted that law enforcement can obtain only the information for which the warrant was issued.8686. R. Crim. 789, 79091 (2013). Representative Kelly Armstrong suggested that geofence warrants should be considered contents within the Electronic Communications Privacy Act of 1986 (ECPA), Pub. A single geofence request could include data from hundreds of bystanders. The key to writing Chatrie compliant geofence warrants is a narrow scope and particularized probable cause. Enter a serial number to review your eligibility for support and extended coverage. Police charged a man with robbery of the bank a year earlier after accessing phone-location data kept by Google. See Coolidge v. New Hampshire, 403 U.S. 443, 467 (1971) (explaining that particularity guarantees that intrusions are as limited as possible). Oops something is broken right now, please try again later. In subsequent decisions, the Court reinforced the notion that probable cause for a single physical location cannot be widely extended to nearby places. Some ask for an initial anonymized list of accounts, which law enforcement will whittle down and eventually deanonymize.6565. Typically, a geofence warrant calls on Google to access its database of location information. The . This Note presumes that geofence warrants are Fourth Amendment searches. Their increasingly common use means that anyone whose commute takes them goes by the scene of a crime might suddenly become vulnerable to suspicion, surveillance, and harassment by police. and geographic area delineated by the geofence warrant. Even more strikingly, this level of intrusion is often conducted with little to no public safety upside. The conversation has started and must continue in Congress.183183. 18 U.S.C. Access to the storehouse by law enforcement continues to generate controversy because these warrants vacuum the location . 20 M 392, 2020 WL 4931052, at *45 (N.D. Ill. Aug. 24, 2020). 84/ S. 296, would prohibit government use of geofence warrants and reverse warrants, a bill that EFF also supports. While geofence warrants are a fairly new tactic, surveillance of Black activists is not. Law enforcement has increasingly relied on technology companies to provide information about individual suspects to aid their investigations, sometimes voluntarily but most often in response to court orders.4040. In a legal brief, Google said geofence requests jumped 1,500% from 2017 to 2018, and another 500% from 2018 to 2019. 1181 (2016). MetLife, Inc. v. Fin. While the government may argue that officer discretion remains cabined at this step because it requests additional information about only a narrowed list of individuals, there are two flaws with this response. KRWEa7JC^z-kPdhr_ 3J*d 0G -p2K@u&>BXQ?K2`-P^S J:9EU(2U80A#[P`##A-7P=;4|) J(D/UJK`%h(X!v`_}#Y^SL`D( :BPH:0@K?> Z4^'GdA@`D.ezE|k27T G+ev!uE5@GSIL+$O5VBEUD 2t%BZfJzt:cYM:Tid3t$ Wisconsin,2121. . Zack Whittaker, Minneapolis Police Tapped Google to Identify George Floyd Protesters, TechCrunch (Feb. 6, 2021, 11:00 AM), https://techcrunch.com/2021/02/06/minneapolis-protests-geofence-warrant [https://perma.cc/9ACT-G98Q]. 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. Ventresca, 380 U.S. at 107; Locke v. United States, 11 U.S. (7 Cranch) 339, 348 (1813). Id. Similarly, geofence warrants in Florida leaped from 81 requests in 2018 to more than 800 last year. No. United States v. Lefkowitz, 285 U.S. 452, 464 (1932). 18-mj-00169 (W.D. 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. See, e.g., Affidavit for Search Warrant at 23, United States v. Chatrie, No. Implicit in this understanding is the idea that what is searched by the warrant is only the data in the location history database associated with the particular place and time for which information is requested. Courts and legislatures must do a better job of keeping up to ensure that privacy rights are not diminished as technology advancesregardless of how effective those capabilities might be at solving crimes.186186. Geofence warrants that allow law enforcement to collect location data on mobile device users for criminal probes are under attack by civil rights groups and public defenders; they say the warrants . All requests from government and law enforcement agencies outside of the United States for content, with the exception of emergency circumstances (dened below in Emergency Requests), must comply Id. Because it is rare to search an individual in the modern age. See id. But in a dense city, even a relatively narrow geofence warrant would inevitably capture innocent citizens visiting not only busy public streets and commercial establishments, but also gyms, medical offices, and religious sites, revealing, by easy inference, political and religious associations, sexual orientation, and more.123123. The warrants constitutional defect its generality is cured by its spatial and temporal restrictions, even though the warrant still names no individualized suspect. nor provide the exact location being searched.161161. Other tech companies, such as Uber, Lyft, Snapchat, and Apple have previously been approached for location data requests but they were unsuccessful. All rights reserved. Clayton Rice, K.C. IV (emphasis added); see also Fed. Ever-expanding cloud storage presents more risks than you might think. The trick is knowing which thing to disable. Steele, 267 U.S. at 503. The practice of using sweeping geofence warrants has been adopted by state and federal governments in Arizona,1212. Law enforcement investigators have also made geofence requests to tech companies including Apple, Snapchat and Uber. Torres v. Puerto Rico, 442 U.S. 465, 471 (1979). . and companies often specify that they may provide this data to law enforcement in response to warrants or subpoenas.3737. 279, 33940 (2004); Margaret Raymond, Down on the Corner, Out in the Street: Considering the Character of the Neighborhood in Evaluating Reasonable Suspicion, 60 Ohio St. L.J. 388 U.S. 41 (1967). About a month after the robbery, state law enforcement officials obtained a geofence warrant from . Critics noted that such a bill could penalize anyone attending peaceful demonstrations that, because of someone elses actions, become violent. Id. Google and other private companies act[] as. I believe that iPhones that have Google apps like Gmail or Youtube running in the foreground have the capability to report location to Google. Between 2017 and 2018, Google saw a 1,500% increase in geofence requests. Law enforcement agencies frequently require Google to provide user data while forbidding it from notifying users that it has revealed or plans to reveal their data.55. . Carpenter, 138 S. Ct. at 2218. Perhaps the best that can be said generally about the required knowledge component of probable cause for a law enforcement officers evidence search is that it raise a fair probabilityor a substantial chance of discovering evidence of criminal activity.139139. This list is and will always be a work in progress and new warrants will be added periodically. 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. 2012); Susan W. Brenner & Leo L. Clarke, Fourth Amendment Protection for Shared Privacy Rights in Stored Transactional Data, 14 J.L. Compare United States v. Ross, 456 U.S. 798, 821 (1982) ([A] warrant that authorizes an officer to search a home for illegal weapons also provides authority to open closets, chests, drawers, and containers in which the weapon might be found.), with Arson, 2020 WL 6343084, at *10 (When the court grants a warrant for a unit in [an] apartment building for evidence of a wire fraud offense, it does not grant a warrant for that entire floor or the entire apartment building, but rather the specific apartment unit where there is a fair probability that evidence will be located.). In most cases, the information is in the form of latitude and longitude coordinates derived . 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Another covered solely a small L-shaped roadway,168168. for Just., Cellphones, Law Enforcement, and the Right to Privacy, https://www.nbcnews.com/news/us-news/google-tracked-his-bike-ride-past-burglarized-home-made-him-n1151761, https://int.nyt.com/data/documenthelper/764-fdlelocationsearch/d448fe5dbad9f5720cd3/optimized/full.pdf, https://www.wral.com/scene-of-a-crime-raleigh-police-search-google-accounts-as-part-of-downtown-fire-probe/17340984, https://www.mprnews.org/story/2019/02/07/google-location-police-search-warrants, https://www.phoenixnewtimes.com/news/google-geofence-location-data-avondale-wrongful-arrest-molina-gaeta-11426374, https://www.cnet.com/news/geofence-warrants-how-police-can-use-protesters-phones-against-them, https://www.wired.com/story/creepy-geofence-finds-anyone-near-crime-scene, https://www.forbes.com/sites/thomasbrewster/2018/10/23/feds-are-ordering-google-to-hand-over-a-load-of-innocent-peoples-locations, https://gothamist.com/news/manhattan-da-got-innocent-peoples-google-phone-data-through-a-reverse-location-search-warrant, https://www.nytimes.com/2021/03/05/us/politics/trump-proud-boys-capitol-riot.html, https://www.theverge.com/2019/8/28/20836855/reverse-location-search-warrant-dragnet-bank-robbery-fbi, https://www.thedailybeast.com/manhattan-da-cy-vance-made-google-give-up-info-on-everyone-in-area-in-hunt-for-antifa-after-proud-boys-fight, https://www.nytimes.com/interactive/2019/04/13/us/google-location-tracking-police.html, https://www.apnews.com/828aefab64d4411bac257a07c1af0ecb, https://policies.google.com/terms/information-requests, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3301257, https://transparency.twitter.com/en/reports/information-requests.html, https://www.microsoft.com/en-us/corporate-responsibility/law-enforcement-requests-report, https://www.uber.com/us/en/about/reports/law-enforcement, https://transparencyreport.google.com/user-data/overview, https://www.statista.com/statistics/232786/forecast-of-andrioid-users-in-the-us, https://www.idc.com/promo/smartphone-market-share/os, https://themanifest.com/mobile-apps/popularity-google-maps-trends-navigation-apps-2018, https://www.fastcompany.com/90452990/this-unsettling-practice-turns-your-phone-into-a-tracking-device-for-the-government, https://www.washingtonpost.com/technology/2019/11/21/bank-robber-accuses-police-illegally-using-google-location-data-catch-him, https://www.forbes.com/sites/thomasbrewster/2019/12/11/google-gives-feds-1500-leads-to-arsonist-smartphones-in-unprecedented-geofence-search, https://www.wsj.com/articles/how-political-groups-are-harvesting-data-from-protesters-11592156142, https://www.buzzfeednews.com/article/jasonleopold/george-floyd-police-brutality-protests-government, https://techcrunch.com/2021/02/06/minneapolis-protests-geofence-warrant, https://appleinsider.com/articles/18/03/19/police-are-casting-a-wide-net-into-the-deep-pool-of-google-user-location-data-to-solve-crimes, https://www.pewresearch.org/internet/fact-sheet/mobile, https://www.documentcloud.org/documents/3519211-Edina-Police-Google-Search-Warrant-Redacted.html, https://www.supremecourt.gov/oral_arguments/argument_transcripts/2009/08-1332.pdf, https://www.c-span.org/video/?474236-1/heads-facebook-amazon-apple-google-testify-antitrust-law, https://www.brennancenter.org/sites/default/files/2019-08/Report_Cell_Surveillance_Privacy.pdf, https://www.cnet.com/news/google-is-giving-data-to-police-based-on-search-keywords-court-docs-show. . 08-1332), https://www.supremecourt.gov/oral_arguments/argument_transcripts/2009/08-1332.pdf [https://perma.cc/237H-X9DN] (statement of Kennedy, J.) and not find a cell phone on the person,142142. These reverse warrants have serious implications for civil liberties. In listing the things to be seized, a warrant must list all the data that law enforcement intends to collect throughout the entirety of Googles process, which includes, at least, the latitude/longitude coordinates and timestamp of the reported location information of each device identified by Google in step one.173173. To protect individual privacy and dignity against arbitrary government intrusions,4848. U. L. Rev. Alamat: Jln. L. Rev. Va. June 14, 2019). It would seem inconsistent, therefore, to argue that there is a high probability that perpetrators do not have their phones. AlphaBay was the largest online drug bazaar in history, run by a technological mastermind who seemed untouchableuntil his tech was turned against him. Which UI design tool should I use in 2020? This sends a Parts of the fediverse have been in something of an uproar recently over an experimental search service that was under development called (appropriately enough) Searchtodon. at 552. Zachary McCoy went for a bike ride on a Friday in March 2019. at *5 n.6. Either way, judges consider only the warrant immediately before them and may not think through how their proposed tests will be extrapolated.179179. With permission from a judge, they allow law enforcement to obtain anonymized data from Google from almost any device that was in a certain geographic . and cases122122. Otherwise, privacy protections would be left largely to the discretion of law enforcement rather than the judiciary or legislature.8989. . Orin S. Kerr, Searches and Seizures in a Digital World, 119 Harv. There is also often the risk of obtaining information about individuals in their homes an intrusion that has always been unreasonable without particularized probable cause.124124. Id. Part II begins with the threshold question of when a geofence search occurs and argues that it is when private companies parse through their entire location history databases to find accounts that fit within a warrants parameters. Thus far, however, these warrants have been involved in solving robbery, burglary, and murder cases. Police around the country have drastically increased their use of geofence warrants, a widely criticized investigative technique that collects data from any user's device that was in a specified area within a certain time range, according to new figures shared by Google. Geofencing itself simply means drawing a virtual border around a predefined geographical area. See, e.g., Search Warrant (Fla. Palm Beach Cnty. 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. Geofence warrants are amongst the many new ways policing has . Lab. Last year alone, the company received over 11,550 geofence warrants from federal, state, and local law enforcement. These warrants often do not lead to catching perpetrators2222. If you have a warrant you need, or a template you feel would be good to add please email shortb@jccal.org. Carpenter v. United States, 138 S. Ct. 2206, 2217 (2018); Riley, 573 U.S. at 385. . That line, we think, must be not only firm but also bright. (quoting Payton v. New York, 445 U.S. 573, 590 (1980))). But to the extent that law enforcement has discretion, that leeway exists only after it is provided with a narrowed list of accounts step two in Googles framework. This understanding is consistent only with treating step one as the search.8888. Execs. Assn, 489 U.S. 602, 61314 (1989); Camara v. Mun. In fact, geofence warrants, like most warrants, are almost certainly judicial records, which are the quintessential business of the publics institutions6262. The Reverse Location Search Prohibition Act, A. Courts have already shown great concern over technologies such as physical tracking devices,9797. Google Amicus Brief, supra note 11, at 45. See Skinner v. Ry. Second, this list is often quite broad. does anyone know what happend to this or how i could do it? In practice, inquiry into probable cause for time will likely overlap with the preliminary question of whether geofence warrants are searches. Snapchat and Apple, too. It means that an idle Google search for an address that corresponds to the scene of a robbery could make you a suspect. Minnesota,1515. at *7. ) There is, additionally, the age-old critique that judges do not understand the technologies they confront. Their support is welcome, especially since. 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, e.g., Application for Search Warrant (Minn. Hennepin Cnty. Until now, geofence warrants have largely gone uncontested by U.S. judges, with rare . the Court found no probable cause to search thirty blocks to identify a single laundromat where heroin was probably being sold.116116. Now, Googles transparency report has revealed the scale at which people nationwide may have faced the same violation. Google Amicus Brief, supra note 11, at 89. Harris, 568 U.S. at 244; Pringle, 540 U.S. at 371. If geofence warrants are constitutional at all, it must be because courts understand geofence searches more narrowly: as the production of data directly responsive to the warrant, step two of Googles framework. Ct., 387 U.S. 523, 528 (1967). Berger, 388 U.S. at 57. 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. The major exception is Donna Lee Elm, Geofence Warrants: Challenging Digital Dragnets, Crim. See Valentino-DeVries, supra note 25. at 498. Presumably, this choice is because the search requested by the government seems limited on the warrant applications face to the specific geographic coordinates and timestamps provided. On the one hand, individuals have a right to be protected against rash and unreasonable interferences with privacy and from unfounded charges of crime.131131. The size of the area may vary. See Jon Schuppe, Google Tracked His Bike Ride Past a Burglarized Home. . (June 12, 2019), https://www.pewresearch.org/internet/fact-sheet/mobile [https://perma.cc/7WWT-NLPP]. Jennifer Valentino-DeVries, Tracking Phones, Google Is a Dragnet for the Police, N.Y. Times (Apr. 2019). The figures, published Thursday, reveal that Google has received thousands of geofence warrants each quarter since 2018, and at times accounted for about one-quarter of all U.S. warrants that . from Android usersapproximately 131.2 million Americans4343.