In United States v. Karo, 468 U.S. 705, 104 S. Ct. 3296, 82 L. Ed. 2d 530 (1984), the government installed a beeper in a container of ether with the permission of the owner, which was thereafter acquired by the defendant and used to track his movements. 468 U.S. at 708-09. Karo asserted that the installation of the beeper violated his Fourth Amendment rights, but the Supreme Court disagreed, noting that the barrel into which the beeper had been placed belonged to law enforcement at the time of placement and therefore the installation was consensual.Id. at 711. In Karo there simply was no initial trespass to challenge. Further, when the Court turned to the issue of the monitoring of the beeper, it did not address whether its continued presence constituted a search. Rather, the Court characterized the continued presence of the beeper as going toward whether there was a seizure, noting that for purposes of a seizure even if the beeper's presence was a technical trespass it did not impact the use of the barrel in any meaningful way. Karo, 468 U.S. at 712-13. Whether a particular action constitutes an unlawful seizure is a separate inquiry from whether that same action constitutes an unlawful search.See id. Karo, then, does not stand for the unqualified proposition that one who comes into possession of an object or vehicle only after a tracking device is installed lacks standing to object to its presence and use as an unlawful search. Rather, that case merely stands for the proposition that a defendant cannot assert a Fourth Amendment violation based on a trespass in the absence of a trespassory installation, and that the continued presence of the monitoring device is not a seizure.