Whether a different test is required for the seizure of data contained on a device than the test laid out in United States v. Jacobsen

In United States v. Jacobsen , 466 U.S. 109, 113 (1984), this Court held that “[a] ‘seizure’ of property occurs when there is some meaningful interference with an individual’s possessory interests in that property.” The Court of A ppeals for the Armed Forces, however, held—regarding the seizure of data under Article 131e, Uniform Code of Military Justice, 10 U.S.C. § 931e (2016)—tha t a seizure is complete when the authority seizing the property “has possession of the property and exercises dominion over it to the exclusion of all others.” The question presented is whether, regarding the seizure of data contained on a device, a different test is required than the one la id out by this Court in Jacobsen .