As happened in the Supreme Court cases of Georgia v. Randolph, 547 U.S. 103 (2006) and United States v. Jones, 565 U.S. 400 (2012), the Sixth Circuit has used property law concepts to interpret the Fourth Amendment while misunderstanding what the property laws in force. US v. Jones held that the fourth amendment was violated when police put a tracking device on a car because that would have been a trespass to chattels. Most states, however, do not recognize a trespass to personal property unless it is damaged or commandeered. In an extension of Jones,the Sixth Circuit found a violation of car owners' property rights (and a violation of the fourth amendment) when parking attendants drew chalk lines on car tires to keep track of how long they had been there for the purpose of parking laws. Taylor v. City of Saginaw, 922 F.3d 328 (6th Cir. 2019). Chalk lines wash off in the rain or when driving and would not traditionally have led to liability for trespass. Nonetheless, the 6th Circuit interpreted Jonesto hold that a common law trepass happens whenever there is "intentional physical intrusion, regardless of how slight." While that is true of trespass to real property, it has never been historically true of trespass to chattels. Perhaps states will change their common law rules to copy the Supreme Court's understanding, but perhaps not.