Opposition Letter — Flock Safety ALPR / Mass Surveillance Page 1 [Your Full Name] [Your Street Address] [City, State ZIP Code] [Your Email Address] | [Your Phone Number] [Month Day, 2026] [City Council / Mayor / County Commission] [City Hall / Government Building Address] [City, State ZIP Code] Re: Vehement Opposition to the Deployment, Expansion, or Continuation of Flock Safety Automated License Plate Reader (ALPR) Cameras and Related Mass Surveillance Technology Dear [Mayor / Councilmembers / Commissioners / Officials]: I write as a [resident / taxpayer / concerned citizen] of [City/County] and as a firm believer in the United States Constitution to vehemently and unequivocally oppose any further use, expansion, renewal, or retention of Flock Safety’s automated license plate reader (ALPR) network—or any comparable mass-surveillance ALPR system—in our community. These systems are not “public safety tools.” They are an unconstitutional, suspicionless dragnet that creates a permanent, searchable digital dossier of every driver’s movements, associations, and lawful activities. They violate the Fourth Amendment, chill First Amendment freedoms, enable documented abuses, and impose profound costs on privacy that far outweigh any claimed public-safety benefits. I demand that you immediately terminate any existing Flock contract, order the permanent deletion of all retained data, prohibit future deployment, and hold a public hearing with full transparency on the system’s actual use and costs. I. Fourth Amendment Violations: Warrantless Mass Surveillance of the “Whole of Our Movements” The Supreme Court has repeatedly held that the government may not use technology to assemble a detailed chronicle of a person’s physical movements without a warrant supported by probable cause. In Carpenter v. United States (2018), the Court ruled that prolonged cell-site location tracking constitutes a search because it reveals “the whole of [a person’s] physical movements.” The mosaic theory—individual data points that, when aggregated, reveal intimate details of life—applies with even greater force here. Flock’s national network (now exceeding 100,000 cameras across more than 5,000 agencies) generates approximately 20 billion license-plate reads every month . The average American vehicle is scanned roughly 70 times per month. Each “Vehicle Fingerprint” captures not only the plate but make, model, color, bumper stickers, roof racks, damage, and other unique features—even without a readable plate. Data is retained (typically 30 days by default, longer in some jurisdictions) and is searchable nationwide by any participating agency without a warrant, probable cause, or judicial oversight. Multiple federal lawsuits have challenged this exact architecture as an unconstitutional search: • In Schmidt v. City of Norfolk (E.D. Va.), the Institute for Justice sued over ~172–200 Flock cameras that make it “functionally impossible to drive anywhere without being tracked.” Although the district court granted summary judgment to the city in January 2026 (holding the current density insufficient to reconstruct “the whole” of movements), it expressly warned that “as the number and capabilities of ALPR cameras expand, the constitutional balancing could conceivably tip the other way.” The case is on appeal to the Fourth Circuit; a recent Supreme Court geofence ruling (June/July 2026) strengthens the plaintiffs’ position by treating indiscriminate location dragnets as searches requiring warrants. • Parallel class actions are pending or advancing in San José (474+ cameras), Boulder, San Francisco, and elsewhere, all alleging that warrantless querying of the Flock database violates the Fourth Amendment. • Courts have already recognized that denser networks or longer retention would cross the constitutional line. Our community must not wait for that inevitable tipping point. Opposition Letter — Flock Safety ALPR / Mass Surveillance Page 2 Photographing a plate in public is not the issue. Assembling a retroactive, AI-enhanced, multi-jurisdictional location history of every law-abiding driver—without individualized suspicion—is. II. First Amendment Chilling Effects and Political Surveillance The right to free speech, association, and peaceful assembly is hollow if the government can later reconstruct who attended a protest, a gun-rights rally, a religious service, a medical appointment, or a political meeting. EFF analysis of more than 12 million Flock search logs (December 2024–October 2025) revealed hundreds of searches by more than 50 federal, state, and local agencies explicitly tied to protest activity—including the 50501, Hands Off, and No Kings demonstrations. Agencies have targeted known activist groups. A single query can search tens of thousands of cameras nationwide. This creates precisely the “suffocating atmosphere of surveillance” the Framers designed the First and Fourth Amendments to prevent. Law-abiding residents will reasonably self-censor, avoid open-carry events, ranges, or rallies for fear of future political or bureaucratic targeting. III. Documented Abuses, Mission Creep, and Real-World Harm Even if the system were constitutional, its real-world operation is intolerable: • Officer abuse : Flock’s own Chief Legal Officer has acknowledged stalking of ex-partners as “the most common form of abuse.” A Georgia police chief was arrested after using the system to stalk and harass; multiple Kansas officers misused it similarly. Audit logs exist but are purely reactive. • Immigration and federal overreach : Despite Flock’s claims that customers “own” the data and federal access is opt-in, audits have revealed thousands of ICE/CBP/immigration-related searches of local data—even in jurisdictions with explicit policies against it (Dayton: 7,100+ immigration searches; Mountain View: hundreds of thousands of unauthorized federal and out-of-state searches; Woodburn, OR and dozens of others canceled contracts after discovering the same). At least 53 cities and counties across 20+ states have terminated or refused Flock contracts over unauthorized federal access and privacy violations. • Other weaponization : A Texas officer used the national network to hunt a woman who obtained a self-managed abortion. Mission creep is rampant: traffic enforcement (cell-phone use), school residency checks, employment background investigations, and even noise complaints. • Errors with real human costs : Institute for Justice research documents at least 24 cases (majority since 2023) of innocent motorists stopped at gunpoint, detained, or jailed because of ALPR misreads or human error. Flock claims ~93% accuracy; even that implies over a billion erroneous reads monthly. Roughly 1-in-10 plates have state misidentification. Fewer than 1% of all scans are connected to any crime. • Data leakage and opacity : National “lookup” settings have been enabled without agency knowledge; private HOA and business cameras feed the same pool; FOIA redaction failures have exposed millions of targets. IV. Corporate Attitude and Ineffectiveness Flock Safety CEO Garrett Langley has publicly dismissed privacy concerns by claiming that a license-plate reader is “the dumbest way” to do surveillance because phones already track everyone, and that critics who map publicly visible cameras (DeFlock) form a “terroristic organization” whose “primary motivation is chaos.” He has stated, “I don’t think it’s my job” to police how law enforcement misuses the tool he sells, and has framed opposition as attacks on police rather than legitimate constitutional concerns. These are not the words of a company that respects civil liberties. They are the words of a company that has built a multi-billion-dollar surveillance empire on the backs of every driver’s data while externalizing all accountability. Claimed crime-clearance benefits (Flock’s own self-reported figures) do not justify turning public roadways into a permanent panopticon. Targeted, warrant-based tools already exist. Blanket collection does not. V. Our Demands For the foregoing reasons—constitutional, practical, and moral—I demand that [City Council / Governing Body]: 1. Immediately terminate any existing Flock Safety (or equivalent ALPR) contract and remove all cameras. 2. Order the permanent, verifiable deletion of all historical Flock data associated with our jurisdiction. Opposition Letter — Flock Safety ALPR / Mass Surveillance Page 3 3. Enact a permanent ban on the acquisition or use of networked ALPR systems that enable suspicionless, multi-jurisdictional location tracking without a warrant. 4. Require a public hearing, full release of all search audit logs, contracts, and usage statistics, and an independent privacy and constitutional impact assessment before any future consideration of similar technology. 5. Support state and federal legislation mandating warrants for ALPR database queries, strict retention limits (e.g., 24–72 hours unless tied to an active investigation), and absolute prohibitions on sharing with federal immigration agencies absent a judicial warrant. The Constitution is not a suggestion. The right to travel anonymously on public roads, to associate freely, and to live free of perpetual government cataloguing of one’s every movement is not a partisan issue—it is an American one. Cities from Cambridge to Lynnwood to Dayton to Santa Cruz have already chosen liberty over this technology. [City] must do the same. I am prepared to organize fellow residents, support litigation if necessary, and hold this body publicly accountable for any decision that further entrenches this unconstitutional system. I respectfully request a written response within 14 days detailing the steps you will take. Respectfully submitted, ________________________________ [Your Full Name] Opposition Letter — Flock Safety ALPR / Mass Surveillance Page 4 References American Civil Liberties Union. (2026, June 25). Fight creepy ALPR cameras: Get the Flock out https://www.aclu.org/campaigns-initiatives/get-the-flock-out Carpenter v. United States, 585 U.S. 296 (2018). Electronic Frontier Foundation. (2025, November). How cops are using Flock Safety’s ALPR network to surveil protesters and activists. https://www.eff.org/deeplinks/2025/11/how-cops-are-using-flock-safetys-alpr-network-surveil-protesters-and-activists Electronic Frontier Foundation. (2025, December 30). EFF’s investigations expose Flock Safety’s surveillance abuses: 2025 in review. https://www.eff.org/deeplinks/2025/12/effs-investigations-expose-flock-safetys-surveillance-abuses-2025-review Electronic Frontier Foundation. (2026, March 26). Traffic violation! License plate reader mission creep is already here. https://www.eff.org/deeplinks/2026/03/traffic-violation-license-plate-reader-mission-creep-already-here Institute for Justice. (2026, July 1). Dozens of innocent motorists have been pulled over, detained at gunpoint, or jailed due to AI license plate camera errors. https://ij.org/dozens-of-innocent-motorists-have-been-pulled-over-detained-at-gunpoint-or-jailed-due-to-ai-licens e-plate-camera-errors/ Institute for Justice. (2026, January 27). Hampton Roads residents will appeal court decision upholding Norfolk’s license plate reader surveillance. https://ij.org/press-release/hampton-roads-residents-will-appeal-court-decision-upholding-norfolks-license-plate-reader-surveillance/ Koebler, J. (2024, October 21). Lawsuit argues warrantless use of Flock surveillance cameras is unconstitutional. 404 Media https://www.404media.co/lawsuit-argues-warrantless-use-of-flock-surveillance-cameras-is-unconstitutional/ Langley, G. (2025–2026). Public statements on privacy, DeFlock, and Flock Safety technology (including characterizing camera-mapping activists as a “terroristic organization” and stating “I don’t think it’s my job” to prevent police misuse of the system). Schmidt v. City of Norfolk, No. 2:24-cv-342 (E.D. Va. Jan. 27, 2026), appeal pending , No. 26-1227 (4th Cir.). Supreme Court of the United States. (2026). Geofence warrant decision holding that indiscriminate location data collection constitutes a Fourth Amendment search requiring a warrant [strengthening challenges to dragnet ALPR systems]. TechSpot / multiple outlets. (2026, June 29–30). Flock Safety crosses 100,000 cameras as 53 cities cancel over unauthorized federal data access; systems scanning ~20 billion vehicles monthly. https://www.techtimes.com/articles/319317/20260629/flock-safety-crosses-10 0000-cameras-53-cities-cancel-over-unauthorized-federal-data-access.htm Various municipal audits and news reports (2025–2026). Documented immigration-related searches of local Flock data (e.g., Dayton, OH: 7,100+ searches; Mountain View, CA unauthorized federal access; Woodburn, OR; Lynnwood, WA; Cambridge, MA) and more than 50 jurisdictions that terminated contracts over privacy and data-sharing concerns.