In Carpenter v United States, the Supreme Court struggled to modernize twentieth-century search and seizure precedents for the “Cyber Age.” Twice previously this decade the Court had tweaked Fourth Amendment doctrine to keep pace with advancing technology, requiring a search warrant before the government can either peruse the contents of a cell phone seized incident to arrest or use a GPS tracker to follow a car’s long-term movements.
Caminker, Evan H. "Location Tracking and Digital Data: Can Carpenter Build a Stable Privacy Doctrine?" Sup. Ct. Rev. 2018 (2019): 411-81.