Reply Brief
The following is excerpted from the Reply Brief of the Petitioner as submitted to the U.S. Supreme Court on October 26, 2011. Respondent’s central contention is that GPS surveillance of a vehicle’s public movements for any period of time amounts to a Fourth Amendment search. That position — which is far broader than the court of appeals’ holding — fails. Although GPS technology is more advanced than the beeper technology used to follow a vehicle in Knotts, it reveals the same type of information — the movements of a car on “public thoroughfares” — in which Knotts held that a…
