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I never thought of chalking a tire as:

>trespass for the purpose of gathering incriminating information and therefore a Fourth Amendment violation when done without a warrant

But I guess when phrased that way it kinda makes sense.

That surprises me, I thought they would have said the intrusion was too minimal and that it merely confirms an earlier observation rather than gathering more information on the vehicle or its owner. The judge suggested taking photographs of the parked cars or notes of their position instead, but it strikes me that an easier approach might be to just leave some small object in front of one wheel.
(not US resident, but I see this trend of overthinking and filing lawsuits in the EU, too)

Cases like this add complexity to society where it's not necessary. The solution is to have a society where people believe the officers, and officers who are not nitpicking and mild enough to wait some more minutes.