Whose line is it anyway? Probable cause and historical cell site data

In most contexts, the US Supreme Court has treated warrantless searches as presumptively unreasonable under the Fourth Amendment. The Fourth Amendment's plain language, which protects the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, arguably does not address all technological changes, including electronic communications (as electronic communications are not "houses," "papers," or "effects"). Although allowing the government access to historical cell site data to use as evidence in a criminal proceeding aids law enforcement, legislators must recognize the risks that flow from allowing the government to retrieve cell phone location information without probable cause.