When Can Your iPhone Put You Behind Bars?
State v. Contreras-Sanchez Decision
On April 15, 2026, the Minnesota Supreme Court issued a significant decision in State v. Contreras-Sanchez, a case that squarely addresses modern digital privacy in the context of geofence warrants and cell phone location data. The decision, authored by Justice Sarah E. Hennesy, reverses and remands the lower court’s ruling, providing new guidance on the constitutional limits of law enforcement access to sensitive digital information.
Geofence Warrants and Digital Privacy
A “geofence warrant” is a relatively new investigative tool that allows law enforcement to request information about all cell phones that were present in a specific geographic area during a particular time window. These warrants typically target tech companies like Google, which store vast troves of users’ location data.
In their recent decision, the Court held that Minnesotans do have a reasonable expectation of privacy in the location data that Google and other third-party providers collect from their cell phones. The Court reasoned that the scope and sensitivity of this data go well beyond older records that were previously interpreted regarding the Fourth Amendment, such as hotel registries. While a hotel registry provides a snapshot in time, third-party data can reveal a comprehensive outline of your daily movements, so long as you have your internet-connected devices on your person. As the Court explained, even a short window of location data can “reveal the most private moments of a person’s life, including their familial, political, professional, religious, and sexual associations.” The government’s ability to create a “catalog of a person’s physical movements” is a privacy concern that the Minnesota Constitution directly addresses.
Geofence Warrants: Allowed, But with Important Constraints
In an important clarification, the court declined to hold that all geofence warrants are categorically prohibited as “general warrants” under the Minnesota Constitution. Instead, the Court found that these warrants can be constitutional if supported by probable cause and sufficiently particular in scope. This is where it can get tricky for law enforcement—they must distinctly clarify in their warrant what exactly is being tracked, why it is being tracked, and for how long.
The Court found that the warrant application in this case established a “fair probability” that Google’s servers would contain evidence related to the crime and thus satisfy probable cause. Importantly, the Court held that the government is not required to demonstrate probable cause for every individual whose data might be swept up by a geofence warrant, only that there is probable cause to believe relevant evidence will be found in the databases they search.
A Crucial Limitation
However, the Court identified a substantial issue with the Contreras-Sanchez-warrant: it required particularity. The warrant gave law enforcement “unchecked discretion” to determine which device IDs inside the geofence could be subject to further, more intrusive searches. This lack of specificity, the court held, violates Article I, Section 10 of the Minnesota Constitution, which guards against unreasonable searches and seizures by requiring warrants to be specific about what is to be searched or seized.
The decision emphasizes that Minnesota courts interpret their Constitution independently from the U.S. Supreme Court’s interpretation of the Fourth Amendment. While federal case law may be persuasive, it is not binding; the Minnesota Supreme Court has reaffirmed its responsibility to safeguard Minnesotans’ rights and their personal data.
The Contreras-Sanchez decision marks an important evolution in Minnesota’s digital privacy law, affirming that location data is protected by the state constitution and that, while geofence warrants are not to be held unconstitutional immediately, if they do not have particularity as to what is being searched, they are likely to be held in violation of the Minnesota Constitution. Law enforcement must ensure that such warrants are both supported by probable cause and drafted with sufficient particularity to prevent unchecked government intrusion into Minnesotans’ private lives.
This case sets an important precedent for balancing public safety with individual privacy as technology continues to reshape the landscape of criminal investigations. There is no doubt that the technological landscape will continue to grow, and with it, the courts will have to continue interpreting how these developments affect the public’s privacy.
What Does This Mean for You?
Your phone tracks your every move, and law enforcement knows it. Digital privacy laws and technology are changing fast, and courts are constantly reinterpreting the rules. You need a defense team that understands the latest legal developments and how they affect your rights. At North Star Criminal Defense, we’re always on top of these changes to protect you. If law enforcement comes with a warrant, call us at (651) 330-9678.