Having wrestled with the difficult issues presented by emerging surveillance technologies, which has resulted in a divided opinion in Jones regarding the proper constitutional standard, it appears unlikely that the Court will address similar issues again anytime soon. It seems foreseeable that in a few years the Court may need to address these constitutional standards again-perhaps as they apply to data derived from GPS-enabled smart phones, or the use of technological data available from factory-installed vehicle tracking systems. With this in mind, it seems likely that the ever-increasing speed of advancing technology will determine the pace at which the Court revisits these difficult questions.
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