Filed May 29, 2013
Several state legislatures have expressly limited authority to obtain warrants for GPS devices to law enforcement agencies acting pursuant to a validly obtained warrant. See, e.g., Cal. Penal Code § 637.7; Utah Code Ann. §§ 77-23a-7, 77-23a-15.5; Minn. Stat. §§ 626A.35; Fla. Stat. §§ 934.06, 934.42; S.C. Code. Ann. § 17-30-140; Okla. Stat., tit. 13 §§ 176.6, 177.6; Haw. Rev. Stat. §§ 803-42, 803-44.7; 18 Pa.Cons.Stat. § 5761. 13 employee's office. Critical to the Supreme Court's decision to uphold that search was its observation that "[g]overnment offices are provided to employees for the sole purpose of facilitating the work of an agency.