Yale Law Journal Online has a great new paper entitled "Tiny Constables and the Cost of Surveillance: Making Cents Out of United States v. Jones." The authors attempt to explain the motivations of the concurring Justices in Jones (all 5 of whom would support a broader rule protecting citizens from GPS monitoring).
The authors' approach is empirical: They calculate the actual-dollar-cost of various forms of police surveillance, ranging from manual surveillance (when police tail a vehicle in order to learn where a person goes), to beeper surveillance (devices that send out a signal that police must then manually follow), to modern GPS surveillance. They conclude that the advent of GPS surveillance has reduced police surveillance costs by about ten-fold over the old beeper method.
The authors then tie this observation to Orin Kerr's theory of equilibrium adjustment. That theory explains the Court's Fourth Amendment jurisprudence on the basis that the Court seeks to maintain a balance of privacy over time; whenever there are major changes in police technology that reduce individual privacy--or, conversely, when there are changes that enable individuals to remain more secure than before--the Court adjusts its rules to maintain the status quo of privacy. (If you are interested in Fourth Amendment theory, you should read Kerr's paper on equilibrium adjustment. It's all the rage right now).
The authors conclude that the ten-fold reduction in police surveillance costs is what triggered the equilibrium adjustment that 5 Justices proposed in the Jones concurrences: Police surveillance has simply become too cheap to continue applying the old beeper rules to modern GPS surveillance. The Court hadn't previously felt the need to make an adjustment when beeper surveillance came along, because that technology only reduced police costs by about half.
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