¶ 79. (concurring). I join the majority's conclusion that the order authorizing law enforcement to install and monitor a Global Positioning System (GPS) tracking device on Sveum's vehicle constituted a valid warrant and that law enforcement's execution of the warrant was reasonable. Majority op., ¶ 3.1 write separately to clarify that in this case, the police officers appropriately sought judicial approval because they intended to install or monitor the tracking device in private areas. Given the *413complexity and sophistication of GPS tracking, see, e.g., id., ¶¶ 61-70, I believe that the Wisconsin legislature should consider expressly requiring court authorization of the installation and monitoring of such tracking devices and should consider legislatively setting appropriate parameters and standards for their use. Said legislative action would be consistent with analogous Wisconsin statutes that currently require court authorization of the interception of wire, electronic, or oral communications, see Wis. Stat. §§ 968.28-968.31, and the installation and use of a pen register or a trap and trace device, see Wis. Stat. §§ 968.34-968.37. See also 18 U.S.C. § 3117 (2009); Fed. R. Crim. E 41. However, pursuant to United States v. Knotts, 460 U.S. 276 (1983), it remains my position that installing and monitoring a GPS tracking device on a vehicle in a public area does not constitute a search or seizure within the meaning of the Fourth Amendment. See also United States v. Garcia, 474 F.3d 994 (7th Cir. 2007).
¶ 80. In this case, the police officers appropriately sought judicial approval because they intended to install or monitor the tracking device in private areas. That point is made clear by Detective Mary Ricksecker's affidavit and request for authorization to place and monitor the GPS tracking device on Sveum's vehicle. She averred in relevant part:
[I]n order to effectively conduct the long term surveillance of the Target Vehicle, your affiant or assistant law enforcement personnel, may have to enter the premises located at 6685 County Trunk K, Iowa County, Wisconsin or 2426 Valley Street, Cross Plains, Dane County, Wisconsin,1 for the purpose of installing, monitoring, *414maintaining and retrieving the aforementioned Global Positioning System (GPS) tracking device.
. . . [Y]our affiant is often required to obtain a key to operate the vehicle for temporary times and move the vehicle to a secure location to install the device and to open both the engine compartment and the trunk area of the vehicle for installation. Your affiant requests permission to do the above acts in order to secretly install the device.
Your affiant is aware that persons involved in criminal activities or conspiracies maintain the means and fruits of their violations, often in remote locations including garages, homes and storage sheds....
It is likely that the vehicle your affiant wishes to monitor will be taken into private as well as public places [;] therefore your affiant respectfully requests the court[']s permission to install and monitor the tracking device inside such private and public areas and the affiant requests permission to obtain a key to operate the motor vehicle, if necessary, and requests permission to use the same methods to retrieve the device....
Accordingly, it is clear from Detective Ricksecker's affidavit that law enforcement intended to install the GPS tracking device on Sveum's vehicle by entering a private residence and operating the vehicle and intended to track the vehicle inside private locations. Indeed, the circuit court's order provides that "[t]his matter came before the court at the request of Detective Mary Ricksecker to place and monitor an electronic tracking device on a vehicle that may enter private areas." Because Detective Ricksecker and her accompanying police officers intended to install or monitor the *415tracking device on Sveum's vehicle in private areas, they appropriately sought judicial approval. Absent a warrant or exigent circumstances, the monitoring of a tracking device in a private area, a location not open to visual surveillance, violates the Fourth Amendment rights of those who have a justifiable interest in the privacy of that area. United States v. Karo, 468 U.S. 705, 714-15 (1984). "At the risk of belaboring the obvious, private residences are places in which the individual normally expects privacy free of governmental intrusion not authorized by a warrant, and that expectation is plainly one that society is prepared to recognize as justifiable." Id. at 714.
¶ 81. Federal judges have express authorization to issue warrants for the installation and use of tracking devices. See 18 U.S.C. § 3117; Fed. R. Crim. E 41(b)(4). The 2006 amendments to Federal Rule of Criminal Procedure 41 "reflect[] the view that if the officers intend to install or use the device in a constitutionally protected area, they must obtain judicial approval to do so." Fed. R. Crim. E 41(b) advisory committee's note. Upon receipt of an affidavit or other information, an authorized federal judge "must issue the warrant if there is probable cause ... to install and use a tracking device." Fed. R. Crim. E 41(d)(1). Importantly, Rule 41's requirements for tracking-device warrants reflect the complexity and nuances of GPS tracking. See, e.g., Fed. R. Crim. E 41(e)(2)(C) (providing that a tracking-device warrant must "specify a reasonable length of time that the device may be used," not to exceed 45 days from the date the warrant was issued, and must command the officer to complete installation "within a specified time no longer than 10 calendar days"); 41(f)(2) (providing that the executing officer must return the warrant to the designated judge and *416serve a copy on the person who was tracked or whose property was tracked "[w]ithin 10 calendar days after the use of the tracking device has ended").
¶ 82. Similar to Federal Rule of Criminal Procedure 41 and consistent with orders authorizing the interception of wire, electronic, or oral communications, see Wis. Stat. §§ 968.28-968.31, and the installation and use of a pen register or a trap and trace device, see Wis. Stat. §§ 968.34 — 968.37, the Wisconsin legislature should consider expressly providing for court orders authorizing the installation and monitoring of a tracking device and should consider setting appropriate parameters. Express authorization and guidance would alleviate the problems that arise when evaluating tracking-device warrants under our general statutory scheme on search warrants. See majority op., ¶¶ 61-70.
¶ 83. Again, in this case, the police officers appropriately sought judicial approval because they intended to install or monitor the tracking device on Sveum's vehicle in private areas. Consequently, I join the majority's conclusion that the order authorizing law enforcement to install and monitor a GPS tracking device on Sveum's vehicle constituted a valid warrant and that law enforcement's execution of the warrant was reasonable. However, it remains my position that installing and monitoring a GPS tracking device on a vehicle in a public area does not constitute a search or seizure within the meaning of the Fourth Amendment.2 Therefore, in such instances, a search warrant *417—while certainly desirable — may not be necessary. See Fed. R. Crim. E 41(b) advisory committee's note (providing that if law enforcement "intend[s] to install and use the device without implicating any Fourth Amendment rights, there is no need to obtain the warrant"). Placing a GPS tracking device on the undercarriage of a vehicle while the vehicle is parked in a public area does not constitute a seizure. Garcia, 474 F.3d at 996 (concluding that law enforcement "did not 'seize' the car *418in any intelligible sense of the word" because "[t]he device did not affect the car's driving qualities, did not draw power from the car's engine or battery, did not take up room that might otherwise have been occupied by passengers or packages, [and] did not even alter the car's appearance"). Moreover, tracking a vehicle in public areas does not constitute a search, Knotts, 460 U.S. at 281-85, because "[a] person travelling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another," id. at 281. For that same reason, a person driving in a vehicle has no reasonable expectation of privacy in the fact that he or she arrived on private property after leaving a public roadway. Id. at 281-82. The driver voluntarily conveys such movement to whoever wishes to observe. The Fourth Amendment does not prohibit law enforcement officers from augmenting with appropriate technology their natural ability to conduct visual surveillance. See id. at 282.
¶ 84. In summary, I write separately to clarify that in this case, the police officers appropriately sought judicial approval because they intended to install or monitor the tracking device in private areas. Similar to Federal Rule of Criminal Procedure 41 and consistent with orders authorizing the interception of wire, electronic, or oral communications, see Wis. Stat. §§ 968.28-968.31, and the installation and use of a pen register or a trap and trace device, see Wis. Stat. §§ 968.34-968.37, I respectfully invite the Wisconsin legislature to consider expressly providing for court orders authorizing the installation and monitoring of a tracking device and to set appropriate parameters. However, it remains my position that installing and monitoring a GPS tracking device on a vehicle in a *419public area does not constitute a search or seizure within the meaning of the Fourth Amendment.
¶ 85. For the foregoing reasons, I respectfully concur.
The record reveals that these addresses are the residences of Sveum's sister and mother, respectively.
Numerous other courts have similarly held. See, e.g., United States v. Garcia, 474 F.3d 994, 996-97 (7th Cir. 2007) (holding that the Fourth Amendment does not limit the use of new technology so long as the technology is readily available and merely a substitute for an activity that is "unequivocally not a search" like tracking a vehicle on public highways); United *417States v. Mciver, 186 F.3d 1119, 1126-27 (9th Cir. 1999) (concluding that the act of placing a magnetized tracking device on the defendant's vehicle did not constitute a search and seizure because he had no reasonable expectation of privacy in the undercarriage of his vehicle, and the device did not meaningfully interfere with any possessory interest); United States v. Jones, 451 F. Supp. 2d 71, 88 (D.D.C. 2006) (deeming admissible all data obtained from a GPS tracking device placed on the defendant's vehicle, except for the data obtained while the vehicle was parked in a private garage); United States v. Moran, 349 F. Supp. 2d 425, 467 (N.D.N.Y. 2005) (concluding that the Fourth Amendment was not implicated by law enforcement's attachment and use of a GPS tracking device on the defendant's vehicle because he "had no expectation of privacy in the whereabouts of his vehicle on a public roadway"); Osborn v. Nevada, 44 P.3d 523, 526 (2002) (holding that law enforcement's warrantless attachment of an electronic monitoring device to the bumper of the defendant's vehicle did not constitute an unreasonable search or seizure under the Nevada Constitution because the defendant "had neither a subjective nor an objective expectation of privacy in the bumper of his vehicle"); Stone v. Maryland, 941 A.2d 1238, 1250 (2008) (describing the GPS tracking device attached to the appellant's vehicle as "simply the next generation of tracking science and technology from the radio transmitter 'beeper' in Knotts" and concluding that its use did not implicate the Fourth Amendment because "[t]he appellant and his wife did not have a reasonable expectation of privacy in their location as they traveled on public thoroughfares").