Framing Analysis
The Supreme Court held in a 6-3 decision that a geofence warrant directing Google to produce location data for cellphones near a 2019 Virginia bank robbery constituted a search under the Fourth Amendment. Justice Kagan authored the majority opinion, which recognized a reasonable expectation of privacy in third-party cell-site records but remanded the case for a reasonableness determination without resolving the third-party doctrine. The ruling leaves open questions about the scope of Miller and Smith precedents.