government search of that data did not require a warrant under the Fourth Amendment. This holding was based on the 1979 Supreme Court precedent Smith v. Maryland, in which it was determined that people who voluntarily give data to third-party telecommunications firms could not expect that data to be private. Pauley found no reason why Smith v. Maryland, which concluded that phone metadata was outside the expectation of privacy, would not apply to the NSA's program. Pauley also held that the data collection was supported by the NSA's internal procedures that were in turn authorized under security-oriented statutes like the Patriot Act. According to Keith B. Alexander, the NSA did not perform any pattern analysis or automated data mining to extract additional personal information from every phone user's metadata, but it did need to collect that data to build a database from which individual pieces of information could be searched specifically with a warrant in the future. The court held that this technique was the least intrusive and most practicable method for the NSA's purposes. Pauley was also convinced by the NSA's arguments that the metadata collection program was necessary for protecting America from terrorist attacks, citing purported success stories like the identification of Najibullah Zazi in connection with the New York City Subway bombing plot, Khalid Ouazzani in connection with the New York Stock Exchange bombing plot, and David Headley in connection with the Mumbai bombings and Danish newspaper bombing plots. Pauley concluded that even though the privacy concerns raised by the surveillance program were not "trivial," the potential benefits of surveillance outweighed such considerations. Thus the NSA's surveillance program was found to be in compliance with the Patriot Act. In turn, Pauley avoided the Fourth Amendment considerations of the complaint. The ACLU appealed this ruling to the Second Circuit Court of Appeals. Circuit Court ruling At the Second Circuit, the ACLU argued: On May 7, 2015, the Second Circuit held that "the telephone metadata program exceeds the scope of what Congress has authorized and therefore violates Section 215" of the Patriot Act. This immediately made many NSA surveillance techniques illegal. As a result, the District Court ruling was vacated and that court was instructed to hear any future cases related to the ACLU's complaint. Subsequent developments Shortly after the Circuit Court ruling, which made much of the NSA's phone metadata surveillance program illegal under the provisions of the