Plaintiffs Zhaocheng Anthony Tan, Scott West, and Colin Wolfson sued the City of San Jose, the San Jose Police Department, and Chief of Police Paul Joseph in his official capacity, seeking declaratory and injunctive relief. They are represented by Michael B. Soyfer and Robert Frommer of the Institute for Justice and Daniel Woislaw of Michel & Associates, P.C.
According to the complaint, the city contracted with Flock Safety to deploy 474 cameras that photograph every passing vehicle day and night. The suit alleges the system uses artificial intelligence to analyze images for license plates, vehicle make, color, and distinctive features such as bumper stickers, storing the data in a centralized database.
The filing states the system collected more than 360 million images in 2024. The plaintiffs allege the city reduced data retention from one year to 30 days after public criticism, but contend the change is "symbolic" because a month of tracking still reveals "deep insights into habits, associations, and visits to sensitive locations" including places of worship and healthcare facilities.
The complaint alleges database access is shared with hundreds of government entities across California, producing nearly 2.5 million searches in the last six months of 2025. Officers can run searches based on "hunch, idle curiosity, or even personal animus," according to the filing, which also alleges federal agencies including ICE obtained "side-door" access by asking local officers to run queries on their behalf.
The plaintiffs, all adult San Jose residents, describe themselves in the complaint as "ordinary, law-abiding people trapped in San Jose's dragnet" who drive past the cameras daily. They allege the program creates a "suffocating atmosphere of surveillance" without warrants, probable cause, or individualized suspicion.
The suit is brought under the Fourth Amendment, the Civil Rights Act of 1871 (42 U.S.C. § 1983), and the Declaratory Judgment Act.