{
  "title": "Fourth Amendment rulings on plate readers and location tracking",
  "updated": "2026-10-23",
  "note": "Court decisions on whether police use of automated license plate readers (ALPRs), and the location-tracking cases they rest on, is a search under the Fourth Amendment. A row is listed only after its holding was checked against an opinion's own text: the decision itself, or another court's opinion that states it, named in the row. Cases are cited by number; private parties appear by initial. This is a reading list, not legal advice.",
  "update_path": "New rulings are found by a weekly court watch and added here only after their opinion has been read.",
  "rulings": [
    {
      "id": "us-277-438",
      "number": "277 U.S. 438",
      "caption": "Olmstead v. United States",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1928-06-04",
      "technology": "Telephone wiretap",
      "outcome": "not_search",
      "holding": "Tapping telephone wires outside the defendants' homes and offices was not a search or seizure, because there was no physical entry and nothing tangible was taken.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "overruled",
      "status_note": "Katz v. United States (389 U.S. 347) held that its trespass doctrine \"can no longer be regarded as controlling.\" Listed for history.",
      "source": {
        "label": "Opinion of the Court, No. 493",
        "url": "https://www.law.cornell.edu/supremecourt/text/277/438"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-389-347",
      "number": "389 U.S. 347",
      "caption": "Katz v. United States",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1967-12-18",
      "technology": "Listening device on a phone booth",
      "outcome": "search",
      "holding": "Electronically listening to and recording a caller's words in a public phone booth was a search, because the Fourth Amendment protects people, not places, and no physical intrusion is required.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "Overruled Olmstead v. United States (277 U.S. 438). The source of the reasonable-expectation-of-privacy test every later row applies.",
      "source": {
        "label": "Opinion of the Court, No. 35",
        "url": "https://www.law.cornell.edu/supremecourt/text/389/347"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-425-435",
      "number": "425 U.S. 435",
      "caption": "United States v. Miller",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1976-04-21",
      "technology": "Bank records",
      "outcome": "not_search",
      "holding": "A depositor had no legitimate expectation of privacy in bank records of his accounts obtained from the bank by subpoena.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "One half of the third-party rule; Carpenter v. United States (585 U.S. 296) declined to extend it to historical cell-site location records.",
      "source": {
        "label": "Opinion of the Court, No. 74-1179",
        "url": "https://www.law.cornell.edu/supremecourt/text/425/435"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-442-735",
      "number": "442 U.S. 735",
      "caption": "Smith v. Maryland",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1979-06-20",
      "technology": "Pen register (numbers dialed)",
      "outcome": "not_search",
      "holding": "Installing and using a pen register to record the numbers dialed from a home phone was not a search, because a person has no legitimate expectation of privacy in information voluntarily turned over to third parties.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "The other half of the third-party rule; Carpenter v. United States (585 U.S. 296) declined to extend it to historical cell-site location records.",
      "source": {
        "label": "Opinion of the Court, No. 78-5374",
        "url": "https://www.law.cornell.edu/supremecourt/text/442/735"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-460-276",
      "number": "460 U.S. 276",
      "caption": "United States v. Knotts",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1983-03-02",
      "technology": "Radio beeper",
      "outcome": "not_search",
      "holding": "Following a car on public roads with a radio beeper was not a search: a person traveling on public thoroughfares has no reasonable expectation of privacy in movements from one place to another.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "The decision ALPR cases most often cite for the government's side.",
      "source": {
        "label": "Opinion of the Court, 460 U.S. at 281 and 285",
        "url": "https://www.law.cornell.edu/supremecourt/text/460/276"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-468-705",
      "number": "468 U.S. 705",
      "caption": "United States v. Karo",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1984-07-03",
      "technology": "Radio beeper",
      "outcome": "search",
      "holding": "Monitoring a beeper inside a private residence, a place not open to visual surveillance, violated the Fourth Amendment, though installing it in a container with the owner's consent was not a search.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "The limit on Knotts (460 U.S. 276): a beeper on public roads is not a search, inside a home it is.",
      "source": {
        "label": "Opinion of the Court, No. 83-850",
        "url": "https://www.law.cornell.edu/supremecourt/text/468/705"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-476-207",
      "number": "476 U.S. 207",
      "caption": "California v. Ciraolo",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "1986-05-19",
      "technology": "Aerial observation",
      "outcome": "not_search",
      "holding": "Police looking into a fenced backyard with the naked eye from an airplane in public airspace did not violate the Fourth Amendment.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "A leading case for the rule that what is visible from a public vantage point is not protected.",
      "source": {
        "label": "Opinion of the Court, No. 84-1513",
        "url": "https://www.law.cornell.edu/supremecourt/text/476/207"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-533-27",
      "number": "533 U.S. 27",
      "caption": "Kyllo v. United States",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "2001-06-11",
      "technology": "Thermal imaging",
      "outcome": "search",
      "holding": "Using a device not in general public use to explore details of a home that would previously have been unknowable without physical intrusion is a search, presumptively unreasonable without a warrant.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "",
      "source": {
        "label": "Opinion of the Court, No. 99-8508",
        "url": "https://www.law.cornell.edu/supremecourt/text/533/27"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-565-400",
      "number": "565 U.S. 400",
      "caption": "United States v. Jones",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "2012-01-23",
      "technology": "GPS tracker",
      "outcome": "search",
      "holding": "Installing a GPS tracker on a vehicle and using it to follow the vehicle's movements was a search.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "",
      "source": {
        "label": "Opinion of the Court, No. 10-1259 (565 U.S. at 404)",
        "url": "https://www.law.cornell.edu/supremecourt/text/10-1259"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-573-373",
      "number": "573 U.S. 373",
      "caption": "Riley v. California",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "2014-06-25",
      "technology": "Cell phone contents",
      "outcome": "search",
      "holding": "Police generally must get a warrant before searching the digital data on a cell phone seized from a person at arrest.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "",
      "source": {
        "label": "Opinion of the Court, No. 13-132",
        "url": "https://www.law.cornell.edu/supremecourt/text/13-132"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "us-585-296",
      "number": "585 U.S. 296",
      "caption": "Carpenter v. United States",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "2018-06-22",
      "technology": "Cell-site location records",
      "outcome": "search",
      "holding": "The government's acquisition of historical cell-site location records was a search; individuals have a reasonable expectation of privacy in the whole of their physical movements.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "The decision ALPR cases most often cite for the defense's side.",
      "source": {
        "label": "Opinion of the Court, No. 16-402 (585 U.S. at 310 and 313)",
        "url": "https://www.law.cornell.edu/supremecourt/text/16-402"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "sct-146-2193",
      "number": "146 S.Ct. 2193",
      "caption": "Chatrie v. United States",
      "court": "U.S. Supreme Court",
      "level": "supreme",
      "decided": "2026-06-29",
      "technology": "Geofence (phone location history)",
      "outcome": "search",
      "holding": "Police conducted a search when they gained access to a phone's Location History data; an individual has a reasonable expectation of privacy in records about his cell phone's location.",
      "binds": "Every court in the country, including Iowa's.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "The Court vacated and remanded and did not decide whether the good-faith exception saves the evidence; the Fourth Circuit takes that up on remand. Reported at 609 U.S. ___ (page numbers not yet assigned).",
      "source": {
        "label": "Opinion of the Court, No. 25-112",
        "url": "https://www.law.cornell.edu/supremecourt/text/25-112"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "ca4-12-4659",
      "number": "No. 12-4659 (en banc)",
      "caption": "United States v. G.",
      "court": "U.S. Court of Appeals, Fourth Circuit",
      "level": "federal_appeals",
      "decided": "2016-05-31",
      "technology": "Cell-site location records",
      "outcome": "not_search",
      "holding": "Applying the third-party doctrine, the full court held there was no reasonable expectation of privacy in historical cell-site records the government got from the phone company with a court order.",
      "binds": "Federal courts in the Fourth Circuit (Maryland, Virginia, West Virginia, the Carolinas), not Iowa.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "Carpenter v. United States (585 U.S. 296) later held the opposite: getting historical cell-site records is a search.",
      "source": {
        "label": "Published en banc opinion, pp. 11 and 37",
        "url": "https://www.ca4.uscourts.gov/opinions/124659A.P.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "mass-sjc-12750",
      "number": "SJC-12750 (484 Mass. 493)",
      "caption": "Commonwealth v. M.",
      "court": "Massachusetts Supreme Judicial Court",
      "level": "state_high",
      "decided": "2020-04-16",
      "technology": "ALPR (four fixed cameras)",
      "outcome": "not_search",
      "holding": "Data from four fixed ALPR cameras on the ends of two bridges was not a search, though the court said that with enough cameras in enough locations, historical ALPR data would invade a reasonable expectation of privacy.",
      "binds": "Massachusetts courts only.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "",
      "source": {
        "label": "Slip opinion, pp. 2 and 29",
        "url": "https://www.eff.org/files/2020/05/05/mccarthy-sjc-12750_07_opinion.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "ca9-18-10341",
      "number": "No. 18-10341",
      "caption": "United States v. Y.",
      "court": "U.S. Court of Appeals, Ninth Circuit",
      "level": "federal_appeals",
      "decided": "2020-05-04",
      "technology": "Commercial ALPR database",
      "outcome": "not_reached",
      "holding": "The court did not decide whether searching an ALPR database is a search, holding instead that the driver of a rental car kept past its return date could not challenge the search; a concurring judge would have held it was not a search.",
      "binds": "Federal courts in the Ninth Circuit (western states), not Iowa.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "",
      "source": {
        "label": "Published opinion, pp. 2-3",
        "url": "https://www.eff.org/files/2020/05/05/2020-05-04-usvyang-9thciropinion.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "iowa-19-0180",
      "number": "No. 19-0180",
      "caption": "State v. W.",
      "court": "Iowa Supreme Court",
      "level": "state_high",
      "decided": "2021-06-18",
      "technology": "Trash pull (Iowa Constitution)",
      "outcome": "search",
      "holding": "Under article I, section 8 of the Iowa Constitution, an officer in a general criminal investigation who took and opened a resident's trash bags left in an alley for collection needed a warrant first.",
      "binds": "Every Iowa court, under the Iowa Constitution.",
      "binds_iowa": true,
      "status": "decided",
      "status_note": "Decided under Iowa's own constitution, not the Fourth Amendment. Opinion amended August 31, 2021.",
      "source": {
        "label": "Opinion of the court, pp. 24-25",
        "url": "https://www.iowacourts.gov/courtcases/8892/embed/SupremeCourtOpinion"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "ca4-20-1495",
      "number": "No. 20-1495 (en banc)",
      "caption": "L. v. Baltimore Police Department",
      "court": "U.S. Court of Appeals, Fourth Circuit",
      "level": "federal_appeals",
      "decided": "2021-06-24",
      "technology": "Aerial surveillance of a city",
      "outcome": "search",
      "holding": "Because Baltimore's aerial surveillance program let police deduce the whole of individuals' movements, the full court held that accessing its data is a search and its warrantless operation violates the Fourth Amendment.",
      "binds": "Federal courts in the Fourth Circuit (Maryland, Virginia, West Virginia, the Carolinas), not Iowa.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "A civil suit; the court reversed the denial of a preliminary injunction.",
      "source": {
        "label": "Published en banc opinion",
        "url": "https://www.ca4.uscourts.gov/opinions/201495A.P.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "va-norfolk-cr23001500",
      "number": "No. CR23001500-00",
      "caption": "Commonwealth v. B.",
      "court": "Circuit Court of the City of Norfolk, Virginia",
      "level": "state_trial",
      "decided": "2024-05-10",
      "technology": "ALPR (Flock, 172 cameras)",
      "outcome": "search",
      "holding": "Collecting and storing license plate and location information through the city's Flock system was a search that should require a warrant, and the evidence was suppressed.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "Published in Virginia Circuit Court Opinions, vol. 113, p. 316. A later Norfolk order that relied on this ruling was reversed on appeal in an unpublished opinion (Commonwealth v. C., No. 0737-25-1); this ruling was not itself appealed in our records.",
      "source": {
        "label": "Order granting motion to suppress, pp. 1-5",
        "url": "https://www.eff.org/files/2025/09/26/comm_v_bell_va_2024_finding_reop_in_flock_scans89.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "ca5-23-60321",
      "number": "No. 23-60321",
      "caption": "United States v. S.",
      "court": "U.S. Court of Appeals, Fifth Circuit",
      "level": "federal_appeals",
      "decided": "2024-08-09",
      "technology": "Geofence (phone location history)",
      "outcome": "search",
      "holding": "Acquiring Location History data through a geofence warrant is a search, and geofence warrants as described are unconstitutional, though the evidence stood because police relied on the warrant in good faith.",
      "binds": "Federal courts in the Fifth Circuit (Texas, Louisiana, Mississippi), not Iowa.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "Split with the Fourth Circuit's ruling in the case the Supreme Court decided in 2026 (146 S.Ct. 2193).",
      "source": {
        "label": "Published opinion, pp. 1-2 and 21",
        "url": "https://www.ca5.uscourts.gov/opinions/pub/23/23-60321-CR0.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "edva-2-24cv621",
      "number": "No. 2:24cv621",
      "caption": "S. v. City of Norfolk",
      "court": "U.S. District Court, Eastern District of Virginia",
      "level": "federal_district",
      "decided": "2025-02-05",
      "technology": "ALPR (Flock)",
      "outcome": "plausible_claim",
      "holding": "At the motion-to-dismiss stage, the court found the complaint plausibly alleged a violation of a reasonable expectation of privacy, likening the alleged monitoring to the tracking in Carpenter.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "on_appeal",
      "status_note": "A civil suit, not a criminal case. The same court later granted the City summary judgment (the next row), and the plaintiffs' appeal is No. 26-1227 in the Fourth Circuit.",
      "source": {
        "label": "Opinion and Order, ECF No. 29, p. 19",
        "url": "https://storage.courtlistener.com/recap/gov.uscourts.vaed.562101/gov.uscourts.vaed.562101.29.0.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "va-norfolk-cr24000304",
      "number": "No. CR24000304",
      "caption": "Commonwealth v. C.",
      "court": "Circuit Court of the City of Norfolk, Virginia",
      "level": "state_trial",
      "decided": "2025-04-25",
      "technology": "ALPR (Flock)",
      "outcome": "search",
      "holding": "Relying on its earlier ruling in No. CR23001500-00, the court suppressed the warrantless use of the Flock system and a statement that followed it, and denied the rest of the motion.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "reversed",
      "status_note": "The Court of Appeals of Virginia reversed this suppression order on 2025-10-14 and sent the case back for trial (next row). Its unpublished opinion names the defendant and the circuit court's reliance on its earlier ruling, not this case number, so the match is by caption, court and subject.",
      "source": {
        "label": "Order granting motion to suppress in part, p. 1",
        "url": "https://www.eff.org/files/2025/09/26/cr24-304_order_granting_defendants_motion_to_suppress_-_4.25.25.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "va-ctapp-0737-25-1",
      "number": "No. 0737-25-1",
      "caption": "Commonwealth v. C.",
      "court": "Court of Appeals of Virginia",
      "level": "state_appeals",
      "decided": "2025-10-14",
      "technology": "ALPR (Flock, 172 cameras)",
      "outcome": "not_search",
      "holding": "Police did not need a warrant to query the Norfolk Flock database, because the cameras took only pictures of the license plate and vehicle on public roads, and the court reversed the order suppressing the evidence.",
      "binds": "No court outside this case; an unpublished memorandum opinion.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "Reversed the Norfolk Circuit Court order in No. CR24000304 (previous row) and remanded for trial. Not designated for publication, so it is not binding precedent.",
      "source": {
        "label": "Memorandum opinion, pp. 6-8",
        "url": "https://www.courtlistener.com/opinion/10701577/commonwealth-of-virginia-v-ronnie-d-church/"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "ndok-25-cr-00239",
      "number": "No. 25-CR-00239-GKF (2025 WL 2427700)",
      "caption": "United States v. A.",
      "court": "U.S. District Court, Northern District of Oklahoma",
      "level": "federal_district",
      "decided": "2025-08-22",
      "technology": "ALPR (Flock stolen-plate alert)",
      "outcome": "not_search",
      "holding": "The defendant, found in a stolen truck with a stolen plate, lacked standing to challenge the plate-reader use; assuming he had standing, the court held the Flock capture did not violate the Fourth Amendment.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "A live stolen-plate alert, not a search of stored plate history. Later history is not in our records.",
      "source": {
        "label": "Opinion and Order, ECF No. 44, pp. 6 and 8-9",
        "url": "https://storage.courtlistener.com/recap/gov.uscourts.oknd.73413/gov.uscourts.oknd.73413.44.0.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "wdok-cr-25-188",
      "number": "No. CR-25-188-D (2025 WL 2444596)",
      "caption": "United States v. B.",
      "court": "U.S. District Court, Western District of Oklahoma",
      "level": "federal_district",
      "decided": "2025-08-25",
      "technology": "ALPR (Flock)",
      "outcome": "not_search",
      "holding": "Searches of a city's three Flock cameras and a shared statewide plate search did not intrude on an expectation of privacy that society would recognize as reasonable, and the motion to suppress was denied.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "The court said the city could significantly expand its Flock program to the point of pervasive tracking, leaving room for a different result. Later history is not in our records.",
      "source": {
        "label": "Findings of Fact, Conclusions of Law and Order, ECF No. 46, p. 10",
        "url": "https://storage.courtlistener.com/recap/gov.uscourts.okwd.131310/gov.uscourts.okwd.131310.46.0.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "edva-2-24cv621-sj",
      "number": "No. 2:24cv621 (ECF No. 191)",
      "caption": "S. v. City of Norfolk",
      "court": "U.S. District Court, Eastern District of Virginia",
      "level": "federal_district",
      "decided": "2026-01-27",
      "technology": "ALPR (Flock, 176 cameras)",
      "outcome": "not_search",
      "holding": "On summary judgment, the court held that the City's operation of 176 plate-reader cameras in 75 clusters does not constitute a search, and entered judgment for the City.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "on_appeal",
      "status_note": "The same case as the motion-to-dismiss ruling above. The plaintiffs' appeal is No. 26-1227 in the Fourth Circuit; no appellate ruling is in our records.",
      "source": {
        "label": "Opinion and Order, ECF No. 191, p. 31",
        "url": "https://storage.courtlistener.com/recap/gov.uscourts.vaed.562101/gov.uscourts.vaed.562101.191.0.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "edok-cr-25-189",
      "number": "No. CR-25-189-JFH (2026 WL 713083)",
      "caption": "United States v. S.",
      "court": "U.S. District Court, Eastern District of Oklahoma",
      "level": "federal_district",
      "decided": "2026-01-28",
      "technology": "ALPR (turnpike records)",
      "outcome": "not_search",
      "holding": "A magistrate judge found no Fourth Amendment violation in obtaining four months of past turnpike plate-reader records by administrative subpoena, and the district judge adopted the recommendation and denied suppression.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "The recommendation is dated 2026-01-28; the district judge adopted it on 2026-02-10 (ECF No. 138) without discussing plate readers. Later history is not in our records.",
      "source": {
        "label": "Findings and Recommendation, ECF No. 129, p. 10",
        "url": "https://storage.courtlistener.com/recap/gov.uscourts.oked.39167/gov.uscourts.oked.39167.129.0.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    },
    {
      "id": "ca5-25-60163",
      "number": "No. 25-60163",
      "caption": "United States v. P.",
      "court": "U.S. Court of Appeals, Fifth Circuit",
      "level": "federal_appeals",
      "decided": "2026-03-17",
      "technology": "ALPR",
      "outcome": "not_search",
      "holding": "The use of a license plate reader did not constitute a search, and the court affirmed.",
      "binds": "Federal courts in the Fifth Circuit (Texas, Louisiana, Mississippi), not Iowa.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "The Altoona Police Department's technology page cites this ruling. Later history is not in our records.",
      "source": {
        "label": "Published opinion",
        "url": "https://www.ca5.uscourts.gov/opinions/pub/25/25-60163-CR0.pdf"
      },
      "verified": "read_in_full",
      "on_site": "/police"
    },
    {
      "id": "ndok-4-26-cr-00189",
      "number": "No. 4:26-cr-00189-SEH",
      "caption": "United States v. K.",
      "court": "U.S. District Court, Northern District of Oklahoma",
      "level": "federal_district",
      "decided": "2026-10-01",
      "technology": "ALPR (Flock and VehicleManager)",
      "outcome": "search",
      "holding": "A deputy's warrantless query of a month of a driver's plate-reader history, more than 50 sightings across several states, intruded on her reasonable expectation of privacy in the whole of her movements and was a search, and the evidence was suppressed.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "Any appeal is not in our records. The order notes that neither the Tenth Circuit nor the Supreme Court has decided whether ALPR use is a search.",
      "source": {
        "label": "Opinion and Order, ECF No. 62, pp. 29 and 37",
        "url": "https://storage.courtlistener.com/recap/gov.uscourts.oknd.76981/gov.uscourts.oknd.76981.62.0.pdf"
      },
      "verified": "read_in_full",
      "on_site": "/police#oklahoma-flock-ruling"
    },
    {
      "id": "ca-scl-25cv480254",
      "number": "No. 25CV480254",
      "caption": "S. v. City of San Jose",
      "court": "Superior Court of California, County of Santa Clara",
      "level": "state_trial",
      "decided": "2026-10-02",
      "technology": "ALPR (Flock)",
      "outcome": "not_search",
      "holding": "Bound by People v. Cartwright (2024), the court held that drivers have no reasonable expectation of privacy in plate data from cameras aimed at public streets, sustaining the city's demurrer to all three state-law claims without leave to amend.",
      "binds": "No court outside this case.",
      "binds_iowa": false,
      "status": "decided",
      "status_note": "A ruling on the California Constitution's search and privacy provisions, not the Fourth Amendment; it is listed because it rests on the same reasonable-expectation question. A separate federal suit over the same system is reported as pending, and any appeal is not in our records.",
      "source": {
        "label": "Order After Hearing - Demurrer, pp. 1-14",
        "url": "https://www.eff.org/files/2026/10/08/2026.10.02_order_after_hearing_-_demurrer.pdf"
      },
      "verified": "read_in_full",
      "on_site": ""
    }
  ]
}