Earlier this year, the Pennsylvania Supreme Court held that users generally lack a reasonable expectation of privacy in unprotected Google search records, underscoring how aggressively some courts are still applying third-party doctrine principles to digital data. Commonwealth v. Kurtz, 348 A.3d 133 (Pa. 2025). Our previous blog post on Kurtz is available here.

Overview of Commonwealth v. Kurtz

On December 16, 2025, the Pennsylvania Supreme Court held that individuals do not have a reasonable expectation of privacy in general, unprotected Google search records. Commonwealth v. Kurtz, No. 98 MAP 2023 (Pa. Dec. 16, 2025). In this criminal case, law enforcement obtained a so-called “reverse keyword search warrant” from