
To be in compliance with the Fourth Amendment, a search warrant must reflect sufficient probable cause, particularly describing the thing or place to be searched and the property to be seized. The breath of a search warrant application must be limited in scope to those items for which there is probable cause to be seized. Geofence warrants are lawful so long as in compliance with these rules, and while limiting an investigator’s unfettered discretion in deciding whose electronic device to search.
Adbadalla Thabet was tasked with the twice-a-week collection of cash receipts from several of his uncle’s gas stations and depositing those proceeds in a bank in Paramount; a suburb of Los Angeles. Surveillance footage collected at various sites (later viewed by investigators of the Los Angeles Sheriff’s Department) showed that Thabet left his apartment building in Downey at around 7 a.m. on the morning of March 1, 2019, and drove to one of his uncle’s gas stations in Downey to pick up cash proceeds for deposit.
After remaining there for about 15 minutes, he left that gas station at 7:30 a.m. and drove to a second gas station in Bellflower where, at about 9:00 a.m., he met with his brother-in-law. Thabet left this gas station at 9:40 and made a brief stop at a strip mall where he and his brother-in-law inspected some possible income property before ....