United States v. Post, 997 F. Supp. 2d 602

FBI agents found a child pornography image on a website, which embedded metadata that revealed GPS coordinates of where the photo was taken.
Metadata in digital photos often includes the date, time, camera settings, and GPS coordinates from smartphones, unless geo-tagging is disabled.
Using opanda.com, agents retrieved the GPS coordinates from the image, locating it to a home in League City, Texas.
Agents found a residence 100 feet from the location and, at Post’s door, observed a couch matching the photo and obtained his admission that he took and uploaded the image with an iPhone 4.
Post admitted taking about ten photos of a four-year-old girl staying at his home and consented to a search that revealed additional images of suspected child pornography.
Post moved to suppress the metadata as a Fourth Amendment privacy interest, but the court denied the motion, holding no privacy interest in the metadata once the image was uploaded publicly.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether metadata is protected by the Fourth Amendment	Post argues metadata remains private despite uploading image publicly.	Post contends metadata is a privacy interest not relinquished by public posting.	No Fourth Amendment privacy interest in metadata.
Whether the government’s use of metadata to locate Post was a search	Post claims metadata search violated privacy expectations.	Post asserts continuing privacy in metadata despite public upload.	Using metadata did not constitute an unconstitutional search.

United States v. Gomez, 276 F.3d 694 (5th Cir.2001) (two-part test for Fourth Amendment privacy expectations)
United States v. Norman, 448 F.App’x 895 (11th Cir.2011) (no expectation of privacy in image placed in peer-to-peer sharing)
United States v. Dodson, 960 F.Supp.2d 689 (W.D.Tex.2013) (no actual privacy expectation where files exposed to public network)
United States v. Borowy, 595 F.3d 1045 (9th Cir.2010) (public exposure to peers negates privacy expectations)