In People v. Zichwic (2001) 94 Cal.App.4th 944, the police attached a GPS tracking device to the undercarriage of a truck owned by a parolee and suspected burglar, and monitored the truck's movements for about three hours, until the suspect was arrested at the site of a burglary. (Zichwic, supra, 94 Cal.App.4th at pp. 949-950.) The trial court denied the defendant's motion to suppress evidence obtained from the GPS device. The Court of Appeal affirmed, following the Ninth Circuit's holding that the installation of a GPS device on a vehicle is not a search 6 because "'"the undercarriage is part of the car's exterior, and as such, is not afforded a reasonable expectation of privacy."'" (Id. at p. 955)