The district court holds the deputy's plate-reader query "was a search under the Fourth Amendment" done "without a warrant"

On October 1, 2026, Judge Sara E. Hill granted Melisa Kyle's motion to suppress. The opinion holds that Deputy Freddie Alaniz's query of the Flock and VehicleManager plate-reader systems for the Mazda's historical locations, which returned more than 50 records over about a month, was a search under the Fourth Amendment. It finds that the query had no probable cause and no warrant and that, on this record, the only reason for it was the California plate. It calls the systems "a type of indiscriminate mass surveillance." Separately, the opinion holds that Alaniz extended the traffic stop without reasonable suspicion, and it suppresses the evidence that followed.

“This is a type of indiscriminate mass surveillance. It is not targeted on a single individual, as in Carpenter. It is a tool that collects information about all vehicles that pass by any network-connected camera at all times, and it serves up the information to law enforcement on demand. … The Court finds that because the ALPR systems Alaniz used to search Kyle’s historical location information intruded on her reasonable expectation of privacy in the whole of her physical movements, it was a search under the Fourth Amendment. Based on the information in the record, the only reason Alaniz conducted that search was because he saw her license plate was from California. That search was not supported by probable cause, and it was done without a warrant in violation of Kyle’s Fourth Amendment rights.”