GA sustains a geofence warrant linking def to a murder

Georgia sustains a geofence warrant linking defendant to a murder. Jones v. State, 2025 Ga. LEXIS 39 (Mar. 4, 2025):

The warrant applications explained among other things that the suspect was caught on video using a cell phone near the victim’s home, that many cell phones generate Google location history data, and, later, that the movements of a specific cell phone “matched up” with what was known of the suspect’s movements. That information, together with the reasonable inferences and common sense that a reviewing magistrate may draw on in assessing probable cause, gave the magistrate here a substantial basis for concluding that accessing the location history and identifying information sought from Google had a fair probability of helping the police identify the unknown murder suspect in the video. And the warrants satisfied the particularity requirement because they gave the police specific guidance as to what information they were authorized to access — a list of anonymized Google IDs and location history data from devices reporting their locations within 100 meters of the victim’s home during a given time frame, and then identifying information tied to one of those Google IDs — and avoided the kind of unfettered discretion that would pose a particularity problem.