at 614. S8183, 20192020 Leg. 2015); Eunjoo Seo v. State, 148 N.E.3d 952, 959 (Ind. If Google complies, it will supply a list of anonymized data about the devices in the area: GPS coordinates, the time stamps of when they were in the area, and an anonymized identifier, known as a reverse location obfuscation identifier, or RLOI. Specific legislative solutions are beyond the scope of this Note. Individuals would have had to possess extremely keen eyesight and perhaps x-ray vision to have had any awareness of the crime at all.154154. That is because Apple doesn't store location data in a format . Last year alone, the company received over 11,550 geofence warrants from federal, state, and local law enforcement. Lab. 2013), vacated, 800 F.3d 559 (D.C. Cir. [-~P?42r%gS(_: Law enforcement has served geofence warrants to Google since 2016, but the company has detailed for the first time exactly how many it receives. If this is the case, whether the warrant is sufficiently particular and whether probable cause exists should be evaluated not with respect to the database generally, but in relation to the time period and geographic area that is actually searched. This Part explains why the Fourth Amendments warrant requirements should be tied to the scope of the search at step two, then explains what this might mean for probable cause and particularity. and companies often specify that they may provide this data to law enforcement in response to warrants or subpoenas.3737. 7, 2020, 6:22 AM), https://www.nbcnews.com/news/us-news/google-tracked-his-bike-ride-past-burglarized-home-made-him-n1151761 [https://perma.cc/73TP-KBXR]. In the meantime, as law enforcement relies on the warrants, countless more passersby will become collateral damage., 2023 Cond Nast. 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 Albert Fox Cahn, This Unsettling Practice Turns Your Phone into a Tracking Device for the Government, Fast Co. (Jan. 17, 2020), https://www.fastcompany.com/90452990/this-unsettling-practice-turns-your-phone-into-a-tracking-device-for-the-government [https://perma.cc/A4NR-ZRVQ]. See, e.g., Jones, 565 U.S. at 417 (Sotomayor, J., concurring); United States v. Graham, 824 F.3d 421, 425 (4th Cir. Brewster, supra note 14. (Who Defends Your Data?) On January 14, 2020, these rides made him a suspect in a local burglary.22. Stored at Premises Controlled by Google (Pharma I), No. 2006). Geofence Warrants: A Necessary Invasion of Privacy? A general warrant is simply an egregious example of a warrant that is too broad in relation to the object of the search and the places in which there is probable cause to believe that it may be found.128128. Maryland v. Garrison, 480 U.S. 79, 84 (1987). Though some initial warrants provide explicitly for this extra request,7373. (1763) 98 Eng. 'Geofence warrant' unconstitutional, judge rules in Virginia - Police1 R. Crim. In contrast, officers are engaged in the often competitive enterprise of ferreting out crime.5353. While there was likely probable cause to search the businesses where pharmaceuticals were stolen, this probable cause did not extend to other units of the building or neighboring areas.153153. 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. Just., Summer 2020, at 7. . The U.S. Patent and Trademark Office on Tuesday granted Apple a patent for a mobile device monitoring system that uses anonymized crowdsourced data to map out cellular network dead spots. Their support is welcome, especially since. The amount of behind-the-scenes cooperation between Apple-Facebook-Google-et-al and law enforcement would boggle the . and probable cause for an apartment does not justify a search next door.120120. Angela Lang/CNET. This rummaging and the general [a]wareness that the government may be watching chills associational and expressive freedoms.106106. the Court found no probable cause to search thirty blocks to identify a single laundromat where heroin was probably being sold.116116. Particularly describing the former is straightforward. Complaint at 23, Rodriguez v. Google, No. The geofence warrants served on Google shortly after the riot remained sealed. the Fourth Amendment guarantees [t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures and requires that warrants be issued only upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.4949. See, e.g., Global Requests for User Information, Google, https://transparencyreport.google.com/user-data/overview [https://perma.cc/8CQU-943P]. Memorandum from Timothy J. Shea, Acting Admr, Drug Enft Admin., to Deputy Atty Gen., Dept of Just. ; Fed. Google Amicus Brief, supra note 11, at 3. The location data typically comes from Google, who collects data from their Android phone . Ng, supra note 9. 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. Like thousands of other innocent individuals each year, McCoy and Molina were made suspects through the use of geofence warrants.99. New iMac With 'iPad Pro Design Language'. Geofence warrant requests in Virginia grew from 72 in 2018 to 484 in 2020, . 08-1332), https://www.supremecourt.gov/oral_arguments/argument_transcripts/2009/08-1332.pdf [https://perma.cc/237H-X9DN] (statement of Kennedy, J.) Geofence warrants work differently from typical search warrants. Laperruque proposes, at minimum, that law enforcement should be pushed to minimize search areas, delete any data they access as soon as possible, and provide much more robust justifications for their use of the technique, similar to the requirements for when police request use of a wiretap. . Every DJI quadcopter broadcasts its operator's position via radiounencrypted. 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. R. Crim. Google now reports that geofence warrants make up more than 25% of all the warrants Google receives in the U.S., the judge wrote in her ruling. About a month after the robbery, state law enforcement officials obtained a geofence warrant from . Wayne R. LaFave, Search and Seizure: A Treatise on the Fourth Amendment, Jeffrey S. Sutton, 51 Imperfect Solutions, The Political Heart of Criminal Procedure: Essays on Themes of William J. Stuntz, Rachel Levinson-Waldman, Brennan Ctr. (asking whether, if you are trying to text somebody who is simultaneously texting someone else, you will get a voice mail saying that your call is very important to us; well get back to you). W_]gw2OcZ)~kUid]-|b(}O&7P;U {I]Bp.0'-.%{8YorNbVdg_bYg#. Apple, Uber, and Snapchat have . BTS, Baepsae, on The Most Beautiful Moment in Life Pt. First, officers had established the existence of coconspirators using traditional surveillance tools.155155. 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. Each one of these orders could sweep in hundreds or . warrant, "geofence warrants," which are testing the boundaries of the Fourth Amendment. and raise interesting and novel Fourth Amendment questions, they have rarely been studied. Google Data and Geofence Warrant Process | nlsblog.org 20 M 392, 2020 WL 4931052, at *1617 (N.D. Ill. Aug. 24, 2020); In re Search of: Info. 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 Arson, 2020 WL 6343084, at *10; Pharma II, 2020 WL 4931052, at *1617; Pharma I, 2020 WL 5491763, at *6. 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 others, police have targeted the wrong man, or retrieved data on more than 1,000 phones going through the area, raising concerns about how innocent people can be affected by such warrants. But they can do even more than support legislation in one state. Id. What are Geofence Warrants? - Polk Law PLLC Tracking Phones, Google Is a Dragnet for the Police Apple will only provide content in response to a search warrant issued upon a showing of probable cause, or customer consent. 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. IV. at 48081. To revist this article, visit My Profile, then View saved stories. Of the courts that have considered these warrants, most have implicitly treated the search as the point when the private company first provides law enforcement with the data requested step two in Googles framework with no explanation why.7777. Google and other private companies act[] as. In practice, inquiry into probable cause for time will likely overlap with the preliminary question of whether geofence warrants are searches. 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. . Execs. Assn, 489 U.S. 602, 615 (1989). See, e.g., Klayman v. Obama, 957 F. Supp. 1, 2021), https://www.statista.com/statistics/232786/forecast-of-andrioid-users-in-the-us [https://perma.cc/4EDN-MRUN]. 1241, 1245, 126076 (2010) (arguing that [t]he practice of conditioning warrants on how they are executed, id. 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. As it pertains to law enforcement, geofencing begins with officers defining an area of interest and a time period. Some, for example, will expand the search area by asking for devices located outside the search parameters but within a margin of error.6464. Usually, officers identify a suspect or person of interest, then obtain a warrant from a judge to search the persons home or belongings. Minnesota law enforcement has already turned to geofence warrants to identify protesters,109109. Geofence warrants: What they are and why they're controversial 18 U.S.C. . These searches, which occur [w]ith just the click of a button and at practically no expense,102102. 3d 37, 42 (D. Mass. The relevant inquiry is the degree of the Governments participation in the private partys activities. Id. 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. Berger, 388 U.S. at 57. In Ohio, requests rose from seven to 400 in that same time. Do Geofence Warrants Violate the Fourth Amendment? - Lawfare (June 12, 2019), https://www.pewresearch.org/internet/fact-sheet/mobile [https://perma.cc/7WWT-NLPP]. 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. ; Products, supra. Id. A geofence warrant is a warrant that goes to any company capable of tracking your location data through your cellphone. See, e.g., Elm, supra note 27, at 11, 13. and anyone who visits a Google-based application or website from their phone,4444. The number of geofence warrants police submitted to Google has risen dramatically. 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]. Laperruque argues that geofence warrants could have a chilling effect, as people forgo their right to protest because they fear being targeted by surveillance. Geofence and reverse keyword warrants completely circumvent the limits set by the Fourth Amendment. United States v. Jacobsen, 466 U.S. 109, 113 (1984). The Washington Post recently published an op-ed by Megan McArdle titled "Twitter might be replaced, but not by Mastodon or other imitators." The trick is knowing which thing to disable. 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. Otherwise, privacy protections would be left largely to the discretion of law enforcement rather than the judiciary or legislature.8989. When law enforcement seeks CSLI associated with a particular device, it merely asks for information that phone companies already collect, compile, and store.7878. 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. Id. Theres always collateral damage, says Jake Laperruque, senior policy counsel for the Constitution Project at the nonprofit Project on Government Oversight. And that's just Google. 2703(a), (b)(A), (c)(A). 2016). Harris, 568 U.S. at 244; Pringle, 540 U.S. at 371. Ctr. Part III explains that if courts instead adopt a narrow definition of searches, such that only the accounts that fall within the terms of a warrant are considered searched, law enforcement must satisfy the Fourth Amendments probable cause and particularity requirements by establishing that evidence of a crime is likely to be found in a companys location history records associated with a specific time and place and providing specific descriptions of the places searched and things seized. 373, 40912 (2006); see also Jeffrey S. Sutton, 51 Imperfect Solutions 17478 (2018) (explaining the lockstep phenomenon). It means that an idle Google search for an address that corresponds to the scene of a robbery could make you a suspect. . All rights reserved. Id. 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. New figures from Google show a tenfold increase in the requests from law enforcement, which target anyone who happened to be in a given location at a specified time. Geofence Warrants: Useful Crime Solving Tool or Invasive Surveillance Id. ACLU, Public Defenders Push Back Against Google Giving Police Your at 57. CSLI,9999. George Joseph & WNYC Staff, Manhattan DA Got Innocent Peoples Google Phone Data Through a Reverse Location Search Warrant, Gothamist (Aug. 13, 2019, 5:38 PM), https://gothamist.com/news/manhattan-da-got-innocent-peoples-google-phone-data-through-a-reverse-location-search-warrant [https://perma.cc/RH9K-4BJZ]. Geofence Warrants On The Rise - Logically L. Rev. 636(a)(1); Fed. . Id. The avid biker would do loops around his Gainesville, Fla., neighborhood and track his rides with a fitness app on his Android phone. While New York has proposed the first bill outlawing these warrants,182182. The three tech giants have issued a public statement through a trade organization,Reform Government Surveillance,'' that they will support a bill before the New York State legislature. Heads of Facebook, Amazon, Apple & Google Testify on Antitrust Law, supra, at 1:37:13. The major exception is Donna Lee Elm, Geofence Warrants: Challenging Digital Dragnets, Crim. Police charged a man with robbery of the bank a year earlier after accessing phone-location data kept by Google. Other tech companies that collect location data, including Apple, Microsoft, and Uber, receive similar requests each year. 531, 551 (2005) (emphasis added). While this initial list may include dozens of devices, police then use their own investigative tools to narrow the list of potential suspects or witnesses using video footage or witness statements. 775, 84245 (2020). See United States v. Jones, 565 U.S. 400, 402 (2012); United States v. Karo, 468 U.S. 705, 709, 717 (1984). 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. . report. 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. Google has reportedly received as many as 180 requests in a single week.2525. Geofencing is used in advanced location-based services to determine when a device being tracked is within or has exited a geographic boundary. Carpenter v. United States, 138 S. Ct. 2206, 2217 (2018). See Carpenter v. United States, 138 S. Ct. 2206, 2211, 2217 (2018). Geofence warrants, in contrast, allow law enforcement to access private companies deep repository of historical location information,101101. The bill would also ban keyword searches, a similarly criticized investigative tactic in which Google hands over data based on what someone searched for. U.S. Const. 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.). Spy Cams Reveal the Grim Reality of Slaughterhouse Gas Chambers. at *5. Because of their inherently wide scope, geofence warrants can give police access to location data from people who have no connection to criminal activities. Courts have already shown great concern over technologies such as physical tracking devices,9797. Lab. Courts have granted law enforcement geo-fence warrants to obtain information from databases such as Google's Sensorvault, which collects users' historical . Geofence warrants represent both a continuation and an evolution of this relationship. [vi] In current practice, Google requires law enforcement to obtain a single search warrant. Riley v. California, 573 U.S. 373, 403 (2014) (internal quotation marks omitted); see also Marshall v. Barlows, Inc., 436 U.S. 307, 311 (1978) (describing historical opposition to general warrants); Coolidge v. New Hampshire, 403 U.S. 443, 467 (1971); Stanford, 379 U.S. at 48184. The breakthroughs and innovations that we uncover lead to new ways of thinking, new connections, and new industries. As courts are just beginning to grapple seriously with how the Fourth Amendment extends to geofence warrants, the government has nearly perfected its use of these warrants and has already expanded to its analogue: keyword search history warrants. 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. between midnight and 3:00 a.m.), which further limited the warrants scope.171171. Katie Benner, Alan Feuer & Adam Goldman, F.B.I. 20 M 297, 2020 WL 5491763, at *6 (N.D. Ill. July 8, 2020) (rejecting the governments argument that Googles framework curtail[s] or define[s] the agents discretion in a[] meaningful way); see also Arson, 2020 WL 6343084, at *10; Pharma II, 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. 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 WIRED is where tomorrow is realized. Time period should be treated analogously to geographic parameters for purposes of probable cause. Zachary McCoy went for a bike ride on a Friday in March 2019. On the other hand, the government has an interest in finding incriminating evidence and preventing crime.132132. See Arson, 2020 WL 6343084, at *8. Brinegar, 338 U.S. at 176; see also Heien v. North Carolina, 574 U.S. 54, 60 (2014) (To be reasonable is not to be perfect . Publicly, Google is the only tech company that releases information to law enforcement agents in response to geofence warrants. Id. But lawyers for Rhine, a Washington man accused of various federal crimes on January 6, recently filed a motion to suppress the geofence evidence. but to Google or an Apple, saying this is a geographic region . .); 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.). Maine,1414. Emily Glazer & Patience Haggin, Political Groups Track Protesters Cellphone Data, Wall St. J. The company then gathers information about all the devices that 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]. Second, the areas encompassed were drawn narrowly and mostly barren, making it easier for individuals to see across large swaths of the area.156156. for example, an English court struck down a warrant that allowed officials to apprehend[] the authors, printers, and publishers of a publication critical of the government9393. 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. Never fearcheck out our. See Google Amicus Brief, supra note 11, at 14. Yet Google often responds despite not being required to by a court.7575. Ct. Feb. 1, 2017), https://www.documentcloud.org/documents/3519211-Edina-Police-Google-Search-Warrant-Redacted.html [https://perma.cc/7SCA-GGPJ] (requesting this information of suspects accounts along with their Google searches). Step twos back-and-forth reinforces the possibility that a companys entire database could be retrieved and exposed to law enforcement from nonobservable form to observable form. Id. Eighty-one percent have smartphones. What Is A Geofence Warrant? Bank Robbery Accused Snagged Using Google Minnesota,1515. at 41516 (Sotomayor, J., concurring); United States v. Knotts, 460 U.S. 276, 28182 (1983). See Smith v. Maryland, 442 U.S. 735, 742 (1979); United States v. Miller, 425 U.S. 435, 442 (1976). The Mystery Vehicle at the Heart of Teslas New Master Plan, All the Settings You Should Change on Your New Samsung Phone, This Hacker Tool Can Pinpoint a DJI Drone Operator's Location, Amazons HQ2 Aimed to Show Tech Can Boost Cities. This Part argues that the relevant search for Fourth Amendment purposes occurs instead when a private company first searches through its entire database step one in Googles framework and that, as a result, geofence warrants are categorically unconstitutional. See Deanna Paul, Alleged Bank Robber Accuses Police of Illegally Using Google Location Data to Catch Him, Wash. Post (Nov. 21, 2019, 8:09 PM), https://www.washingtonpost.com/technology/2019/11/21/bank-robber-accuses-police-illegally-using-google-location-data-catch-him [https://perma.cc/A9RT-PMUQ]. Now, a group of researchers has learned to decode those coordinates. 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. The existence of probable cause, for example, must be tied not only to whether the database contains evidence of the crime but also to whether probable cause extends to the areas for which location data is requested. See Maryland v. Garrison, 480 U.S. 79, 85 (1987). But geofence warrants do exactly that authorizing broad searches of entire location history databases, simply on the off chance that somebody connected with a crime might be found. Similarly, geofence data could be used as evidence of guilt not just by being loosely associated with someone else in a crowd but by simply being there in the first place. As a result, geofence warrants are general warrants and should be unconstitutional per se. 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.