People v. Meza
312 Cal.Rptr.3d 1
Cal. Ct. App.2023Background
- In March 2019 detectives obtained a geofence search warrant directed to Google seeking location‑history records for devices present in six specified locations and time windows tied to the victim’s movements on the morning he was murdered. The geographic windows were relatively large (circles/rectangles spanning up to several acres) and the cumulative temporal scope exceeded five hours.
- The warrant prescribed a three‑step process: (1) Google to produce an anonymized list of devices in each geofence/timeframe; (2) law enforcement to narrow that list; and (3) Google to provide identifying account information for devices law enforcement deemed relevant.
- Google and the Sheriff’s Department effectively filtered results to devices present in two or more geofence locations; Google returned eight anonymized accounts and later identified eight accounts, two of which led to Meza and Meneses.
- Meza and Meneses were charged with murder; they moved to quash/suppress arguing the geofence warrant violated the Fourth Amendment (lack of particularity and overbreadth) and CalECPA. The trial court denied suppression; both defendants pleaded (Meza guilty to first‑degree murder; Meneses no contest to second‑degree).
- The Court of Appeal held the warrant was supported by probable cause but was insufficiently particular and overbroad under the Fourth Amendment. The court nevertheless affirmed the convictions under the Leon good‑faith exception. The court also concluded the warrant complied with CalECPA.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Meza / Meneses) | Held |
|---|---|---|---|
| Probable cause for geofence warrant | Probable cause existed to search Google’s location history because surveillance placed suspect vehicles with the victim and officers reasonably inferred suspects used phones. | No evidence defendants used phones during relevant times; warrant therefore lacked probable cause to search device location data. | Probable cause existed based on surveillance, officers’ training/experience, and reasonable inferences about phone use. |
| Particularity of the warrant | Warrant sufficiently described the database and records sought (devices within specified coordinates and times). | Warrant left law enforcement with unfettered discretion at steps 2–3 to expand/narrow searches and decide which accounts to deanonymize, violating particularity. | Warrant failed the Fourth Amendment particularity requirement because it gave unbridled discretion to officers to select accounts for deanonymization. |
| Overbreadth of geofence parameters | Areas and timeframes were tailored to the victim’s known movements and surveillance; necessary to capture suspects. | Geofence areas and time windows were excessively large and could capture many uninvolved third parties; officers could have narrowed parameters. | Warrant was overbroad: geographic and temporal windows were not narrowly tailored and risked identifying numerous uninvolved persons. |
| Compliance with CalECPA and remedy | Warrant complied with CalECPA’s requirement to describe information to be seized as appropriate and reasonable; suppression not required under statute. | CalECPA requires naming target individuals/accounts and applications; constitutional defects also create CalECPA violations, so Leon exception should not save evidence. | Warrant satisfied CalECPA (described targets as devices in locations/times); defendants’ statutory argument rejected; Leon good‑faith exception applied to deny suppression. |
Key Cases Cited
- United States v. Leon, 468 U.S. 897 (1984) (establishes good‑faith exception to exclusionary rule)
- Carpenter v. United States, 138 S. Ct. 2206 (2018) (historical location data can implicate Fourth Amendment privacy interests)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause standard for warrants)
- Maryland v. Garrison, 480 U.S. 79 (1987) (particularity requirement prevents general searches)
- People v. Amador, 24 Cal.4th 387 (2000) (particularity requirement’s purpose and flexibility)
- People v. Robinson, 47 Cal.4th 1104 (2010) (warrant particularity and reasonableness principles)
- United States v. Chatrie, 590 F. Supp. 3d 901 (E.D. Va. 2022) (analyzing geofence warrants; particularity and overbreadth concerns)
- In re Search of Information Stored at Premises Controlled by Google, LLC, 481 F. Supp. 3d 730 (N.D. Ill. 2020) (denying geofence warrant where government discretion to deanonymize was unchecked)