Case: Rolando Antuain Williamson v. United States, No. 25-412
Lower Court: Eleventh Circuit
Docketed: 2025-10-06
Status: Denied
Question Presented: 1. Whether a “search” occurs when the government takes a purposeful, investigative act directed toward an individual’s home and curtilage, regardless of whether the individual has a “reasonable expectation of privacy” in the area; and 2. Whether, even under Katz, long-term, continuous, and surreptitious surveillance of an individual’s home and curtilage constitutes a “search.”
On March 23, 2026, the Supreme Court denied certiorari in Williamson v. United States. The petition had attracted notable amicus support, including a brief from the Cato Institute filed November 5, 2025. The government’s two requests for extension before filing its opposition brief suggested the case received serious internal attention before the denial.
Petitioner Rolando Antuain Williamson, represented by Jo-Ann Tamila Sagar, brought a Fourth Amendment challenge arising from the Eleventh Circuit. The petition argued that the Katz reasonable-expectation-of-privacy test fails to adequately protect the home, and that a purposeful-act standard should apply independently of Katz.
The two questions presented reflect a tension the Court has acknowledged but not resolved. The full docket shows Fourth Amendment Scholars also filed an amicus brief supporting the petition.
The denial leaves the underlying doctrinal question unresolved. Practitioners and scholars should watch for future petitions raising similar curtilage and extended-surveillance claims, as the Court’s reluctance here does not foreclose reconsideration when a sharper circuit conflict develops.