Ladonies P. Strong v. United States

In United States v. Jacobsen, 466 U.S. 109, 113 (1984), this Court held that “[a] ‘seizure’ of property occurs when there is some meaningful interference with an individual’s possessory interests in that property.” The Court of Appeals for the Armed Forces, however, held—regarding the seizure of data under Article 131e, Uniform Code of Military Justice, 10 U.S.C. § 931e (2016)—that a seizure is complete when the authority seizing the property “has possession of the property and exercises dominion over it to the exclusion of all others.” The question presented is whether, regarding the seizure of data contained on a device, a different test is required than the one laid out by this Court in Jacobsen. (i)