from a physical sense, how the government controls a person's body (i.e. Roe v. Wade) and other activities such as wiretapping and photography. As important records became digitized, Westin argued that personal data was becoming too accessible and that a person should have complete jurisdiction over their data, laying the foundation for the modern discussion of privacy. New technologies can also create new ways to gather private information. For example, in the United States, it was thought that heat sensors intended to be used to find marijuana-growing operations would be acceptable. Contrary to popular opinion, in 2001 in Kyllo v. United States (533 U.S. 27) it was decided that the use of thermal imaging devices that can reveal previously unknown information without a warrant does indeed constitute a violation of privacy. In 2019, after developing a corporate rivalry in competing voice-recognition software, Apple and Amazon required employees to listen to intimate moments and faithfully transcribe the contents. Police and government Police and citizens often conflict on what degree the police can intrude a citizen's digital privacy. For instance, in 2012, the Supreme Court ruled unanimously in United States v. Jones (565 U.S. 400), in the case of Antoine Jones who was arrested of drug possession using a GPS tracker on his car that was placed without a warrant, that warrantless tracking infringes the Fourth Amendment. The Supreme Court also justified that there is some "reasonable expectation of privacy" in transportation since the reasonable expectation of privacy had already been established under Griswold v. Connecticut (1965). The Supreme Court also further clarified that the Fourth Amendment did not only pertain to physical instances of intrusion but also digital instances, and thus United States v. Jones became a landmark case. In 2014, the Supreme Court ruled unanimously in Riley v. California (573 U.S. 373), where David Leon Riley was arrested after he was pulled over for driving on expired license tags when the police searched his phone and discovered that he was tied to a shooting, that searching a citizen's phone without a warrant was an unreasonable search, a violation of the Fourth Amendment. The Supreme Court concluded that the cell phones contained personal information different than trivial items, and went beyond to state that information stored on the cloud was not necessarily a form of evidence. Riley v. California evidently became a landmark case, protecting the digital protection of citizen's privacy