How has the Court interpreted the argument that moving a few inches does not constitute a search and is much more than trivial for the Fourth Amendment?

"New York", United States of America

The following excerpt is from People v. Goldman, 135 N.Y.S.3d 48, 159 N.E.3d 772, 35 N.Y.3d 582 (N.Y. 2020):

Arizona v. Hicks, 480 U.S. 321, 325, 107 S.Ct. 1149, 94 L.Ed.2d 347 [1987] [holding that moving an object a few inches nonetheless constitutes a search and "is much more than trivial for purposes of the Fourth Amendment" because "(a) search is a search"] ).

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