A federal judge has ruled that law enforcement’s use of automated license plate reader (ALPR) systems to track a motorist’s cross-country travel constitutes an unconstitutional warrantless search, throwing out evidence in a major drug trafficking case.
U.S. District Court Judge Sara Hill issued the ruling in the case of Melissa Kyle, whose vehicle was pulled over by a Tulsa County deputy sheriff. Although authorities ultimately discovered more than 91 pounds of methamphetamine inside the rental car, the court determined that the initial search of private and public ALPR databases violated the Fourth Amendment.
Body camera and in-vehicle footage obtained from court records show Tulsa County Deputy Sheriff Freddie Alaniz driving approximately 60 miles per hour while operating his laptop to search automated tracking systems before he had fully executed the traffic stop. Alaniz noted in the footage that he decided to pull the vehicle over simply because it bore California license plates. According to the court, the officer told colleagues he began running the vehicle’s information through Flock and Vigilant—Motorola’s ALPR system—after watching it pass by on the highway.
During the traffic stop, Alaniz informed Kyle that she was being pulled over for changing lanes without a signal. He asked her to step out of the rental car and sit in his cruiser while she looked up rental documentation. While speaking with Kyle, Alaniz scrolled through a detailed digital map on his in-car laptop displaying her travel history over the preceding 30 days, which included 79 total hits, with roughly 50 recorded during the few-day period she had rented the vehicle.
The tracking data mapped the car’s route from Missouri through Oklahoma, Texas, New Mexico, and Arizona before entering California, and the return journey. Alaniz used the accumulated location records to cross-examine Kyle about the exact dates and locations of her trip. Government attorneys subsequently argued in court that minor discrepancies between Kyle’s statements and the digital logs demonstrated she was dishonest, thereby establishing probable cause for a vehicle search.
After issuing a warning for the lane violation, Alaniz informed Kyle that he intended to question her further, stating that his training suggested short trips to California and back often involved drug transport. When Kyle declined permission for a vehicle search, Alaniz detained her and called for backup. Deputies searched the vehicle and uncovered what Alaniz described in the footage as a “shit-ton of meth.”
Judge Hill rejected the government’s position, ruling that the search of the ALPR databases violated Kyle’s reasonable expectation of privacy regarding her physical movements. The court noted that the officer possessed no reasonable suspicion or warrant to query the tracking networks, rendering the subsequent vehicle search and seized evidence inadmissible as “fruit of the poisonous tree.”
Court filings highlighted the vast scope of the surveillance network utilized during the stop. Alaniz’s database searches drew upon cameras operated by numerous entities across multiple states, including a camera owned by a Lowe’s hardware store in Missouri, state police agencies in Texas and New Mexico, and local municipal police departments. In a five-day span, the rental vehicle was captured more than 50 times by 11 different law enforcement agencies.
In her ruling, Judge Hill emphasized that the behavioral factors cited by prosecutors—such as taking long road trips, losing track of days while traveling, crossing state lines, packing luggage, renting cars, and experiencing nervousness during police encounters—are routine experiences shared by everyday travelers. The decision establishes that combing through weeks of automated location history based solely on out-of-state license plates exceeds constitutional boundaries.
