Dragnets Beyond the Warrant: Private Surveillance Brokers and the Fourth Amendment's Blind Spot

Digital Tyranny: a virtual system that infers “perfectly” based on scrubbing away the very intrinsic messy facets of reality our laws strive to protect.

Sat Jul 11 2026
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A couple weeks ago the United States Supreme Court held in a 6-3 decision that police conducted a Fourth Amendment search where they obtained a person's cell phone location data through a Geofence Warrant. The case was Chatrie v. United States, and it revolved around determining a suspect from a bank robbery that happened a couple years prior. The gist is that the content of the search (a few hours of location data) stored in a consented 3rd party data collection service (Mr. Chatrie had consented to Google Map's Location History mechanism at some point) did indeed constitute a Fourth Amendment search.

The majority opinion narrows the Third-Party Doctrine due to their understanding that a typical user will tend to be the only person who views their own information that is located on a 3rd party server, despite that information being voluntarily conveyed to that company's server. Justices Jackson and Sotomayor went as far as to say the warrant gave officers a roving commission to demand more and more data without magistrate approval, with only the 3rd party (Google) being the agent to set limits or stop them. The framework in Chatrie v. United States assumes a framework where courts can police the boundaries of searches. What happens when the data already exists in private hands, outside of any constitutional requirement? To understand why private surveillance systems pose a unique threat, we need to return to the Framers' original anxiety—not about absolute power, but about how systems of measurement and rules reshape human behavior.

Government systems, writ large, operate based in codified rules and regulations to reach towards a principle of justice, fairness, and pursuits of different kinds. We imagine these sorts of classifications and categorizations as rules to guide the mechanized state, powered by persons acting out official roles. But, as James Madison wrote, if men were angels, no government would be necessary. When we look to the Constitution of the United States of America, we can see this very plainly in the ordering of the branches of the Federal Government, down to the powers given the Executive and Legislature, and the lack of description for the Chief Justice. A system to protect itself and those subjected to its power.

We must recognize that the privilege of the Authors, those Founding Framers, in that their understanding of these words' meaning binds all who cosign to it. With this concept (that by describing we instill the writers' views into the discussion of the readers) we see that Framing is everywhere. In the book The Score, Prof. Nguyen describes Metrics this way: a technology that refines and guides our desires and goals towards a certain value perspective outside of ourselves. When you concentrate metrics into one adjudicator (i.e. who facilitates the creation, review, and evaluation), it is a concentration of power. The Framers of the Constitution knew this fear of concentrated power: it's why the Virginians were so against the idea of a Federal government overseeing the united States— they wondered if they were trading one tyrant for another. Or in my labored analogy: one system of metrics (the Crown) for another (compliance to Federal law) that would still lead to their undoing.

Which is why their system works so well: the balancing of powers, the public discourse, and the natural impeding of discussion in congress leading towards more thought for thorny decisions. This acknowledgement reflects that reality is messy and complex: these categories in bureaucracy miss out on the complexity of people, their behavior, and their data (aka property as Justice Gorsuch noted), and how observations of these patterns are not neutral.

But what about decisions made without public input, related to the public? What if there is a third party corporation involved that isn't ambiguous but incentives to assist, or influence a certain outcome? Flock Group inc (DBA Flock Safety) is such a company in my eyes. The facial recognization tech at Madison Square Garden (which recently been exposed as classifying people as Queer without disclosure, tracking one trans athlete for 2 years without notice) is another example of these private public-dragnet repositories of identifying information.

These systems formalize a practice of establishing unasked/unconsented repositories of uniquely identifying information of the public, where law enforcement agencies can simply pay a subscription in order to access, causing an accountability deficit: an inability to audit, no oversight, and no recourse for errors. These surveillance systems are value-laden, meaning they (like our system of laws) imbue meaning and insight based in their categorization systems without anyway to audit (i.e. did MSG verify the sexual identities, or just assumed someone with blue hair is gay?). The people who make these software systems are not pillars of integrity who study the rules of society— they are mercurial software engineers.

These purveyors of security software are encouraged through the mechanisms of the market to find better value proposition for their services, which means creating more versatile tools (i.e. LLM-based query engines) for law enforcement officers to use because asking for a warrant has too much legal friction. Systems like Flock Group Inc's spring up due to the ubiquitous and trivial license plate reader system, which opens the door to the more nefarious functionality of a database that works across state lines.

How do you establish a narrative? In creative writing you let the story unfold for a captive audience. For law, you know the facts but it's the team of lawyers who articulate a defining story by framing facts into a narrative, and it's up to the jury to determine if the plaintiff or defendant are right (or a judge in summary rulings). Surveillance systems, with their arbitrary categorization systems, frame people into subjective stories. If law enforcement using systems like Flock Group Inc or Madison Square Garden's vast database, which have no public audibility with limited transparency of authenticity, which develop their own category system outside of the justice system, to support developing behaviors of the law enforcement, what stories are we allowing to come into existence when these systems label an individual as a person of interest based on some black box system?

Digital Tyranny: a virtual system that infers perfectly based on scrubbing away the very intrinsic messy facets of reality our laws strive to protect.