We will hear argument first this morning in case 25-1-12, Chattery versus United States.

Mr. Unikowski.

Mr. Chief Justice, and may it please the Court, the government conducted a search of petitioner's location history,

and the warrant that purported to authorize that search violated the Fourth Amendment.

The government conducted a search.

The Court should hold that people

have a property interest in their data, in their accounts on the cloud. Location history has the

core attributes of property. Petitioner had a right to exclude, to control, and to destroy.

Additionally, Petitioner had a reasonable expectation of privacy in his location history, given

both its sensitive and revealing nature and the fact that it was stored in his password-protected

account. The warrant violated the Fourth Amendment. The warrant authorized the government

to direct Google to search every single person's account to find those people who were within

the G-offense. That is a general

warrant. Even if the search materialized only when the data was found and exposed to the police,

the warrant would still be unconstitutional because there was not probable cause to search the

virtual private papers of every single person within the geofence merely because of their

proximity to the crime.

Finally, at step two and step three, the search violated the Fourth Amendment

because the warrant gave the police unlimited discretion to decide who to search

while casting Google into the role of magistrate.

I welcome the Court's questions.

How exactly did the warrant violate petitioner's rights at the Fourth Amendment rights at

...