apple geofence warrant

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. As a result, Molina dropped out of school, lost his job, car, and reputation, and still has nightmares about sitting alone in his jail cell.88. In Wilkes v. Wood,9292. A geofence warrant is a warrant that goes to any company capable of tracking your location data through your cellphone. Ct. Rev. March 15, 2022. Usually, officers identify a suspect or person of interest, then obtain a warrant from a judge to search the persons home or belongings. . 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. It should be a last resort, because its so invasive.. Particularity was constitutionalized in response to these reviled general warrants.9595. This Note presumes that geofence warrants are Fourth Amendment searches. 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. 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]. Apple and Facebook remained resolute in their vow not to build back doors into their products for law enforcement to potentially view the private communications of . Courts have granted law enforcement geo-fence warrants to obtain information from databases such as Google's Sensorvault, which collects users' historical . . Probable cause for a van does not extend to a suitcase located within it,119119. Speaking to WIRED last year, Quart called the tools a fishing expedition that violates people's basic constitutional rights., But regulation can only move so fast. After spending several thousand dollars retaining a lawyer, McCoy successfully blocked the release.44. See United States v. Jones, 565 U.S. 400, 430 (2012) (Alito, J., concurring); see also State v. Brown, 202 A.3d 1003, 1012 n.8 (Conn. 2019); Commonwealth v. Estabrook, 38 N.E.3d 231, 237 (Mass. nor provide the exact location being searched.161161. Google and other private companies act[] as. See Stanford, 379 U.S. at 482. But a warrant does not need to describe the exact item being seized,160160. Rooted in probability, probable cause is a flexible standard, not readily, or even usefully, reduced to a neat set of legal rules.136136. Probable cause to search a private companys location records is easily established because evidence of a crime probably exists within these records.141141. Raleigh Police Searched Google Accounts as Part of Downtown Fire Probe, WRAL.com (July 13, 2018, 2:07 PM), https://www.wral.com/scene-of-a-crime-raleigh-police-search-google-accounts-as-part-of-downtown-fire-probe/17340984 [https://perma.cc/8KDX-TCU5] (explaining that Google could not disclose its search for ninety days); Tony Webster, How Did the Police Know You Were Near a Crime Scene? . Just., Summer 2020, at 7. Lab. A coalition of more than 25 reproductive justice, civil liberties, and privacy groups are supporting the bill at introduction. 138 S. Ct. 2206. the information retrieved in response to a geofence warrant is pervasive, detailed, revealing, retroactive, and cheap.3333. 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. Police charged a man with robbery of the bank a year earlier after accessing phone-location data kept by Google. The warrant itself must be particular when presented to a judge for review163163. Many are rendered useless due to Googles slow response time, which can take as long as six months because of Sensorvaults size and the large number of warrants that Google receives.112112. See, e.g., Klayman v. Obama, 957 F. Supp. Id. 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. and raise interesting and novel Fourth Amendment questions, they have rarely been studied. ([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. 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. not due to the accompanying documents or post hoc narrowing by law enforcement or a private company.164164. See, e.g., Search Warrant (Fla. Palm Beach Cnty. See United States v. Patrick, 842 F.3d 540, 54245 (7th Cir. at 1128 (quoting EEOC v. Natl Child.s Ctr., Inc., 98 F.3d 1406, 1409 (D.C. Cir. Geofence warrants enable the government to conduct sweeping searches of cell phone location data for any phone that enters a predefined geographical boundary, or geofence, during limited time frames.2 The rising 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. See, e.g., Global Requests for User Information, Google, https://transparencyreport.google.com/user-data/overview [https://perma.cc/8CQU-943P]. 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]. . 775, 84245 (2020). In the statement released by the companies, they write that, This bill, if passed into law, would be the first of its kind to address the increasing use of law enforcement requests that, instead of relying on individual suspicion, request data pertaining to individuals who may have been in a specific vicinity or used a certain search term. This is an undoubtedly positive step for companies that have a checkered history of being cavalier with users' data and enabling large-scale government surveillance. . Ring Road Utara, Kaliwaru, Condongcatur, Kabupaten Sleman, Daerah Istimewa Yogyakarta 55282. The warrant was thus sufficiently particular. Now, Googles transparency report has revealed the scale at which people nationwide may have faced the same violation. But California's OpenJustice dataset, where law enforcement agencies are required by state law to disclose executed geofence warrants or requests for geofence information, tells a completely different story.. A Markup review of the state's data between 2018 and 2020 found only 41 warrants that could clearly constitute a geofence warrant. 2d 1, 34 (D.D.C. 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. But lawyers for Rhine, a Washington man accused of various federal crimes on January 6, recently filed a motion to suppress the geofence evidence. A Peek Inside the FBI's Unprecedented January 6 Geofence Dragnet Thomas Brewster, Feds Order Google to Hand Over a Load of Innocent Americans Locations, Forbes (Oct. 23, 2018, 9:00 AM), https://www.forbes.com/sites/thomasbrewster/2018/10/23/feds-are-ordering-google-to-hand-over-a-load-of-innocent-peoples-locations [https://perma.cc/EH8L-59ZU]. See, e.g., Affidavit for Search Warrant at 23, United States v. Chatrie, No. Stored at Premises Controlled by Google (Pharma I), No. Cf. EFF proudly joins ACLU California Action and If/When/How to co-sponsor new California legislation to protect people seeking abortion and gender-affirming care from dragnet-style digital surveillance. See Stephen E. Henderson, Learning from All Fifty States: How to Apply the Fourth Amendment and Its State Analogs to Protect Third Party Information from Unreasonable Search, 55 Cath. See id. See Coolidge v. New Hampshire, 403 U.S. 443, 467 (1971) (explaining that particularity guarantees that intrusions are as limited as possible). In other words, the characterization of a geofence warrant as a search in the first place likely relies in part on the prevalence of cell phones. Apple plans to announce ARM transition for all Macs at WWDC 2020. What Is A Geofence Warrant? Bank Robbery Accused Snagged Using Google See Google Amicus Brief, supra note 11, at 1314. Google Bankrupting Apple Privacy Promises by Handing Data to Police Ct. May 9, 2018), https://int.nyt.com/data/documenthelper/764-fdlelocationsearch/d448fe5dbad9f5720cd3/optimized/full.pdf [https://perma.cc/TSL6-GFCD] (issuing an indefinite nondisclosure order); Amanda Lamb, Scene of a Crime? Geofence warrants, in contrast, allow law enforcement to access private companies deep repository of historical location information,101101. In California, geofence warrant requests leaped from 209 in 2018 to more than 1,900 two years later. 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. it is reasonable to believe that the perpetrators phone data can be found in these records. Clayton Rice, K.C. 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. Second, this list is often quite broad. Global Nav Open Menu Global Nav Close Menu and potentially without realiz[ing] the technical details or broad scope of the searches theyre authorizing5656. Brinegar v. United States, 338 U.S. 160, 176 (1949); see also United States v. Di Re, 332 U.S. 581, 595 (1948) (explaining that probable cause functions, in part, to place obstacles in the way of a too permeating police surveillance). 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. Around 5 p.m. on May 20, 2019, a man with a gun robbed a bank near Richmond, Virginia, escaping with $195,000. Rep. 1075 (KB). 19. Another covered solely a small L-shaped roadway,168168. The warrant must still be sufficiently particular relative to its objective: finding accounts whose location data connects them to the crime. Pharma II, No. Modern technology, in removing most practical barriers to surveillance, has ensured that this statement no longer holds. Geofences are a tool for tracking location data linked to specific Android devices, or any device with an app linked to Google Maps. Geofence and reverse keyword warrants completely circumvent the limits set by the Fourth Amendment. Though Apple, Lyft, Snapchat, and Uber have all received these warrants,4646. 20 M 525, 2020 WL 6343084 (N.D. Ill. Oct. 29, 2020). Wilkes, 98 Eng. Ct., 387 U.S. 523, 528 (1967). Geofence warrants issued to federal authorities amounted to just 4% of those served on Google. Here's Techdirt's coverage of two consecutive rejections of a geofence warrant published in June 2020. Google now gets geofence warrants from agencies in all 50 states, Washington, D.C., and the federal government. Similarly, with a. , 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. at *10. these criticisms are insufficient for the purposes of probable cause, which has never required certainty just probability. at 498. I believe that iPhones that have Google apps like Gmail or Youtube running in the foreground have the capability to report location to Google. 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. The conversation has started and must continue in Congress.183183. 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. 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 . Johnson v. United States, 333 U.S. 10, 14 (1948). Potentially, Apple iPhones can report data to Sensorvault under the right conditions. 08-1332), https://www.supremecourt.gov/oral_arguments/argument_transcripts/2009/08-1332.pdf [https://perma.cc/237H-X9DN] (statement of Kennedy, J.) Even assuming that complying with a geofence warrant constitutes a search, there remains a difficult and open threshold question about when the search occurs. Arson, No. This understanding is consistent only with treating step one as the search.8888. Pharma II, 2020 WL 4931052, at *16; see also Groh, 540 U.S. at 557. In Ohio, requests rose from seven to 400 in that same time. For months, Zachary McCoy tracked the distance of his bike rides around his neighborhood in Gainesville, Florida, using his RunKeeper app.11. U. L. Rev. Google is the most common recipient and the only one known to respond.4747. 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 . Geofence Warrants: The Last Piece of the Location Privacy Puzzle . Finds Contact Between Proud Boys Member and Trump Associate Before Riot, N.Y. Times (Mar. 1, 2021), https://www.statista.com/statistics/232786/forecast-of-andrioid-users-in-the-us [https://perma.cc/4EDN-MRUN]. Geofence warrants seek location data on every person within a specific location over a certain period of time. In most cases, the information is in the form of latitude and longitude coordinates derived . and the possibility of the federal government scaling up such surveillance to identify every single person at a protest, regardless of whether or not they broke the law or any suspicion of wrongdoing raises core constitutional concerns.110110. The Reverse Location Search Prohibition Act, A. (June 14, 2020, 8:44 PM), https://www.wsj.com/articles/how-political-groups-are-harvesting-data-from-protesters-11592156142 [https://perma.cc/WEE5-QRF2]. According to the data, "Google received 982 geofence warrants in 2018, 8,396 in 2019 and 11,554 in 2020.". Second, the areas encompassed were drawn narrowly and mostly barren, making it easier for individuals to see across large swaths of the area.156156. New York lawmakers want to outlaw geofence warrants as - Protocol In the past, the greatest protections of privacy were neither constitutional nor statutory, but practical.176176. Just this week, Forbes revealed that Google granted police in Kenosha, Wisconsin, access to user data from bystanders who were near a library and a museum that was set on fire last August, during the protests that followed the murder of George Floyd. Under the Fourth Amendment, if police can demonstrate probable cause that searching a particular person or place will reveal evidence of a crime, they can obtain a warrant from a court authorizing a limited search for this evidence. Execs. Assn, 489 U.S. 602, 614 (1989). 20 M 297, 2020 WL 5491763, at *3 (N.D. Ill. July 8, 2020) (noting that particularity is inversely related to the quality and breadth of probable cause). Emily Glazer & Patience Haggin, Political Groups Track Protesters Cellphone Data, Wall St. J. 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. and reviled tools in law enforcement agencies digital toolbox. 2019). The private search doctrine does not apply because the doctrine requires a private entity independently to invade an individuals reasonable expectation of privacy before law enforcement does the same. Because geofence warrants are a new law enforcement tool, there is no collection of data or guidance for oversight. Apple Inc. - Check Your Service and Support Coverage 20 M 392, 2020 WL 4931052, at *45 (N.D. Ill. Aug. 24, 2020). It's Time for Google to Resist Geofence Warrants and to Stand Up for P. 41(e)(2). The overwhelming majority of the warrants were issued by courts to state and local law enforcement. Instead, it is enough if the description is such that the officer with a search warrant can with reasonable effort and presumably relying on expertise and experience ascertain and identify the place intended.162162. See, e.g., Transcript of Oral Argument at 44, City of Ontario v. Quon, 560 U.S. 746 (2010) (No. Alfred Ng, Geofence Warrants: How Police Can Use Protesters Phones Against Them, CNET (June 16, 2020, 9:52 AM), https://www.cnet.com/news/geofence-warrants-how-police-can-use-protesters-phones-against-them [https://perma.cc/3XEJ-L3KT]. 20 M 525, 2020 WL 6343084, at *6 (N.D. Ill. Oct. 29, 2020). at 117. July 14, 2020). . Orin S. Kerr, Searches and Seizures in a Digital World, 119 Harv. Part I describes the limited judicial and public oversight that these warrants currently receive, then explains the process by which Google responds to them. See Sidney Fussell, Creepy Geofence Finds Anyone Who Went Near a Crime Scene, Wired (Sept. 4, 2020, 7:00 AM), https://www.wired.com/story/creepy-geofence-finds-anyone-near-crime-scene [https://perma.cc/PC3Q-ZCMG]. What kind of information do officers receive? In fact, it is more precise than either CSLI or GPS.3434. . Id. id. In practice, inquiry into probable cause for time will likely overlap with the preliminary question of whether geofence warrants are searches. Geofence location and keyword warrants are new law enforcement tools that have privacy experts concerned. Both iPhone and Android have a one-click button to tap that disables everything. 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 . [-~P?42r%gS(_: 2012). . Last . Mobile Fact Sheet, Pew Rsch. See Carpenter v. United States, 138 S. Ct. 2206, 2211, 2217 (2018). 27012712; Elm, supra note 27, at 9. its text merely requires a warrant issued using the procedures described in the Federal Rules of Criminal Procedure. Google uses its stored location data to personalize advertisements, estimate traffic times, report on how busy restaurants are, and more. Geofence Warrants: The Next Frontier in Privacy Litigation The major exception is Donna Lee Elm, Geofence Warrants: Challenging Digital Dragnets, Crim. L. Rev. See, e.g., Search Warrant, supra note 5. Geofence warrants help police find suspects using Google. A ruling These searches, which occur [w]ith just the click of a button and at practically no expense,102102. . Search Warrant Templates | JCDA Warrant Portal What Are Geofence Warrants | thenextweb Never fearcheck out our. Valentino-DeVries, supra note 42. to produce an anonymized list of the accounts along with relevant coordinate, timestamp, and source information present during the specified timeframe in one or more areas delineated by law enforcement.7070. Geofence Warrants: Useful Crime Solving Tool or Invasive Surveillance 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. Google Amicus Brief, supra note 11, at 1213. from Android usersapproximately 131.2 million Americans4343. ; Products, supra. 2020); State v. Tate, 849 N.W.2d 798, 813 (Wis. 2014) (Abrahamson, C.J., dissenting). 373, 40912 (2006); see also Jeffrey S. Sutton, 51 Imperfect Solutions 17478 (2018) (explaining the lockstep phenomenon). The Gainesville Police Department had gotten something called a geofence warrant granted by the Alachua County court. WIRED is where tomorrow is realized. 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. This Part describes the limited role judges and the public currently play in approving and scrutinizing geofence warrants and how Google responds to them. at *1. Writing Google Geofence Search Warrants | Warrant Builder Geofence warrants are warrants used by police to tech companies for information about devices in specific areas. Alamat: Jln. The geofence warrants served on Google shortly after the riot remained sealed. Other tech companies that collect location data, including Apple, Microsoft, and Uber, receive similar requests each year. Geofence Warrants: Worthy Law Enforcement Tool or Personal Privacy (June 12, 2019), https://www.pewresearch.org/internet/fact-sheet/mobile [https://perma.cc/7WWT-NLPP]. 14, 2018). See Google Amicus Brief, supra note 11, at 14. Coolidge v. New Hampshire, 403 U.S. 443, 467 (1971); see also Riley v. California, 573 U.S. 373, 403 (2014). 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. 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. The article argues that Mastodon is falling into a common trap for open source projects: building a look-alike alternative which improves things a typical user doesnt care As the UK's Online Safety Bill enters its Second Reading in the House of Lords, EFF, Liberty, Article 19, and Big Brother Watch are calling on Peers to protect end-to-end encryption and the right to private messaging online.As we've said before, undermining protections for end-to-end encryption would make Brazils biggest internet connection providers made moderate advances in protecting customer data and being transparent about their privacy practices, but fell short on meeting certain requirements for upholding users rights under Brazil's data protection law, according to InternetLabs 2022 Quem Defende Seus Dados? 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. by a court of competent jurisdiction.6060. and balances two competing interests. 3 0 obj But talking to each other only works when the people talking have their human rights respected, including their right to speak privately. 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. Courts are still largely dealing with the threshold question of whether different forms of electronic surveillance count as searches at all, see sources cited supra note 39, an inquiry that can be avoided through legislative solutions. Google has reportedly received as many as 180 requests in a single week.2525. In order for step twos back-and-forth to be lawful, therefore, the geofence warrant must have authorized these further searches. 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. The avid biker would do loops around his Gainesville, Fla., neighborhood and track his rides with a fitness app on his Android phone. Johnson, 333 U.S. at 14; see also Katz v. United States, 389 U.S. 347, 35859 (1967). The New York bill is still far from passage and impacts just one state. Geofence warrants , or reverse-location warrants, are a fairly new concept. In a legal brief, Google said geofence requests jumped 1,500% from 2017 to 2018, and another 500% from 2018 to 2019. 205, 22731 (2018); Jennifer D. Oliva, Prescription-Drug Policing: The Right to Health Information Privacy Pre- and Post-Carpenter, 69 Duke L.J. . 19-cr-00130 (E.D. Va. June 14, 2019). at 48081. Apple, Uber, and Snapchat have all received similar requests from law enforcement agencies. In 2018, the Associated Press revealed that Google continues to collect location data even when location history tracking is disabled. . Namun tidak seperti beberapa .