The U.S. Court of Appeals for the Fourth Circuit ruled, in U.S. V. Graham, that government access to historical cell site location information, which shows what cell towers a phone was connected to (and thus its owner’s rough location), does not require a warrant under the Fourth Amendment. In so holding, the Fourth Circuit, sitting en banc, reversed a panel ruling from last August and eliminated a circuit split which had existed with the Fifth, Sixth, and Eleventh Circuits. While the Fourth Circuit said its decision was mandated by controlling Supreme Court precedent, and that the “Supreme Court may in the future limit, or even eliminate, the third-party doctrine,” the Supreme Court has thus far seemed uninterested in taking up the issue. Even when the split with the Fourth Circuit existed, it denied without comment the defendant’s petition for certiorari in the Eleventh Circuit case. Now that the Circuits are in agreement, it seems even more unlikely that the Supreme Court will determine that this is an issue worth reviewing any time soon.