United States v. Jones, U.S. 132 S. Ct. 945, 181 L. Ed. 2d 911 (2012) addressed whether attaching a GPS tracking device to the defendant's vehicle and then using the device to monitor the vehicle's movements constituted a search under the Fourth Amendment, ultimately concluding it did. Id. at, 132 S. Ct. at 949. The Fourth Amendment provides that "the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated," and the Court in Jones noted a motor vehicle is indisputably an "effect" under the Amendment. Id. The Court concluded the government had "physically occupied private property for the purpose of obtaining information" and that "such a physical intrusion" would have been a "search" when the Fourth Amendment was adopted. Id. Because the Fourth Amendment's text "reflects its close connection to property," early Fourth Amendment jurisprudence was tied to common-law trespass until later cases deviated from an exclusively property-based approach, ultimately adopting the "reasonable expectation of privacy" test articulated in Justice Harlan's concurrence in Katz v. United States, 389 U.S. 347, 360, 88 S. Ct. 507, 19 L. Ed. 2d 576 (1967). Jones, U.S. at, 132 S. Ct. at 949-50. But the Court in Jones stated "the Katz reasonable-expectation-of-privacy test has been added to, not substituted for, the common-law trespassory test." Id. at, 132 S. Ct. at 952. Consequently, the Court concluded either a trespass or an invasion of privacy, in combination with "an attempt to find something or to obtain information," constitutes a search under the Fourth Amendment. Id. at n.5, 132 S. Ct. at 951 n.5. The Fourth Amendment common-law trespass approach in Jones requires a trespass on one's own personal "effects." Id. at, 132 S. Ct. at 949, 953. In Jones, the defendant was the exclusive driver of a vehicle registered to his wife, and the government did not challenge the Court of Appeals's conclusion that the vehicle's registration did not affect whether the defendant could make a Fourth Amendment-based objection. Id. at n.2, 132 S. Ct. at 949 n.2. Thus the Supreme Court, concluding that if Jones was not the owner "he had at least the property rights of a bailee," nonetheless declined to consider further "the Fourth Amendment significance of Jones's status." Id. And the majority opinion emphasized Jones had "possessed the vehicle at the time the Government trespassorily inserted the information-gathering device"--distinguishing him from someone who takes possession of property upon which a device already has been installed. Id. at, 132 S. Ct. at 952.