[378]*378PATIENCE DRAKE ROGGENSACK, J.
¶ 1. We review a decision of the court of appeals1 affirming the circuit court's judgment2 convicting Michael A. Sveum (Sveum) of aggravated stalking and denying Sveum's post-conviction motion for a new trial. In upholding the judgment of conviction, the court of appeals affirmed the circuit court's denial of Sveum's motion to suppress evidence obtained from a Global Positioning System (GPS) tracking device, which law enforcement attached to Sveum's car. Our focus is on whether the circuit court erred in its denial of Sveum's suppression motion.
¶ 2. Sveum and the State have briefed two issues for purposes of our review: (1) whether the installation of a GPS tracking device to Sveum's car while his car was parked in the driveway of his home and the subsequent electronic monitoring of Sveum's car using the GPS constituted a search or seizure within the meaning of the Fourth Amendment of the United States Constitution and Article I, Section 11 of the Wisconsin Constitution; and (2) whether the court order authorizing the installation and monitoring of a GPS tracking device on Sveum's vehicle constituted a valid warrant and, if so, whether the police reasonably executed the warrant.
¶ 3. We elect not to resolve the first issue, and assume, without deciding, that a search or seizure occurred in this case that required authorization by a warrant. We therefore decide only the second issue, concluding that the order authorizing law enforcement to install and monitor a GPS tracking device on Sveum's vehicle constituted a valid warrant and that [379]*379the officers' execution of the warrant was reasonable. Accordingly, we affirm the decision of the court of appeals.
I. BACKGROUND
¶ 4. In 1996, "Sveum was charged with stalking and harassing Jamie Johnson [(Johnson)], his former girlfriend." State v. Sveum (Sveum I), 220 Wis. 2d 396, 399, 584 N.W.2d 137 (Ct. App. 1998). "He was also charged with violating a harassment injunction for contacting [Johnson] personally and by telephone" and "criminal damage to property." Id. Sveum was convicted of all charges, which the court of appeals affirmed. Id. He was sentenced to 11 years of probation for the stalking conviction that commenced upon serving three consecutive, three-year prison terms for the remaining three convictions. Sveum remained in confinement until his mandatory release date of July 2, 2002, when he was released on probation and parole.
¶ 5. In March 2003, Johnson reported to the police that she believed Sveum was stalking her again. On April 22, 2003, Detective Mary Ricksecker (Ricksecker) requested circuit court authorization to install and monitor an electronic device on Sveum's vehicle. Specifically, she requested to attach a GPS tracking device to Sveum's vehicle, a 1980 black Chevy Beretta Coup with a Wisconsin license plate number of 754 ELL and a Vehicle Identification Number (VIN) of 1G1LZ14A2LY130646, and to monitor the tracking device "inside such private and public areas." She further requested "permission to obtain a key to operate the motor vehicle, if necessary" and "to use the same methods to retrieve the device." Finally, she requested "that the order be authorized for a period of time not to exceed 60 days from the date the order is signed."
[380]*380¶ 6. Ricksecker filed an affidavit in support of this request, alleging that GPS monitoring of Sveum's vehicle "could provide relevant information to the criminal investigation of the crime of stalking." Ricksecker averred the following:
That the affiant is a state certified law enforcement officer currently assigned as Detective with the Madison Police Department. Your affiant has worked full-time as a law enforcement officer for approximately 22 years. Your affiant has investigated numerous cases involving harassing phone calls, violation of restraining orders, domestic violence, sexual assaults and stalking. Your affiant has received formal training in the investigation of stalking and has trained law enforcement officers on the investigation of the crime of Stalking, in violation of Wisconsin Statute 940.32.
On 12-21-1994 Michael A[.] Sveum, dob 08-04-67, was convicted of Violation of a Domestic Abuse Order .... The complain[an]t in the case was Jamie Johnson. On 12-11-1995 Sveum was convicted... of Violation of a Domestic Abuse Order. Your Affiant knows the facts in this case were based on hang-up calls received by Jamie Johnson at her residence.
On 10-09-1996 Sveum was convicted ... of Felony Stalking, Violation of a Harassment Restraining Order, and Harassment. The victim in this case was Jamie Johnson. Your affiant investigated this criminal case and knows the facts of the complaint. Johnson was receiving hang-ups during the course of the criminal behavior, which ceased upon him becoming incarcerated. Two hours after Sveum was released on bail... she reported a hang-up call.
[Sveum] is currently employed in the City of Madison and living at 6685 Cty Tk K Blue Mounds.
[381]*381On 3-28-03 Jamie Johnson a resident in the City of Madison reports that where she currently resides with the phone number is []. Since 3-3-03 thru 4-12-03 she and her housemate have received nine hang-up calls at that number. She reports that the caller ID information lists "PRIVATE". She indicates prior to this they have not had any hang-up calls. Johnson advised your affiant that TDS Metrocom is the service provider for [her phone number]. Your affiant believes the information provided by Johnson to be truthful and reliable as it was gained by her as a witness to the events above.
Your affiant contacted TDS Metrocom for records of the incoming hang-up calls reported by Johnson. Your affiant believes the information kept by TDS ... to be truthful and reliable as it [is] kept in the normal course of business. Your affiant knows that hang-up calls could he criminal harassment or felony stalking.
From the information provided by TDS Metrocom and information from the Dane County 911 dispatch center, your affiant learned the hang-up calls were made from pay phones located at the Meadowood Library 5740 Raymond Rd, Party City located at 223 Junction Rd., American TV located at 2404 W. Beltline hwy, Super America located at 2801 Fish Hatchery Rd, Kohl's food store located at 3010 Cahill Rd, and Kitt's Korner Sports Bar and Grill located at 3738 County Rd P All of these locations are in the County of Dane. Your affiant believes the information provided by 911 Dispatch to be truthful and reliable as it is kept in the normal course of business.
Your affiant has found in the course of this investigation that Michael Sveum is the primary user and/or exercises dominion and control over a 1980 black Chevy Beretta Coup with a Wisconsin license plate number of 754 ELL and a VIN number of 1G1LZ14A2LY130646, which is stored and/or parked at an address of 6685 County Trunk K in Iowa County, Wisconsin or stored or [382]*382parked at 2426 Valley Street, Cross Plains in Dane County, Wisconsin, herein after referred to as "the Target Vehicle."...
[A] records check with the Wisconsin Department of Transportation ... indicate[d] the owner of the aforementioned Target Vehicle ... [is] Michael Sveum with a VIN number of 1G1LZ14A2LY130646, at an address of 2426 Valley Street, Cross Plains, Dane County, Wisconsin.
Your affiant believes that Sveum... maintains dominion and control over as well as being the primary user of the aforementioned vehicle.
Your affiant states that there is probable cause to believe based on the above information that the Target Vehicle is presently being utilized in the commission of a crime to wit, stalking.... Your affiant states that there is probable cause to believe that the installation of a [GPS] tracking device on the Target Vehicle in conjunction with the monitoring, maintenance and retrieval of information from that [GPS] tracking device will lead to evidence of the aforementioned criminal violations including the places of the violation and the means of the violation and the identification of associates assisting in the aforementioned violations.
Your affiant states that the [GPS] tracking device, which is covertly placed on a criminal suspect's automobile, is equipped with a radio satellite receiver, which, when programmed, periodically records, at specified times, the latitude, the longitude, date and time of readings and stores these readings until they are downloaded to a computer interface unit and overlaid on a computerized compact disc mapping program for analysis.
[383]*383That based upon the affiant's experience, the [GPS] tracking devices internal battery packs limited use necessitates the use of the suspect's automobile battery power in order to effectively install, monitor, and maintain the [GPS] tracking device over an extended period of time ... .3
Your affiant is aware that persons involved in criminal activities or conspiracies maintain the means and fruits of their violations, often in remote locations including garages, homes and storage sheds. Your affiant believes that the installation of the [GPS] tracking device has been shown to be a successful supplement to visual surveillance of the vehicle due to the inherent risks of detection of manual, visual surveillance by the target of law enforcement personnel. The [GPS] tracking device lessens the risk of visual detection by the suspect and is generally considered more reliable since visual surveillance often results in the loss of sight of the Target Vehicle.
¶ 7. On the same day Ricksecker requested authorization, the circuit court issued an order granting her request to install and monitor a GPS tracking device on Sveum's vehicle. The court concluded that "[b]ased on the information provided in the affidavit submitted by Detective Ricksecker, the court finds that there is probable cause to believe that the installation of a tracking device in the below listed vehicle is relevant to an on-going criminal investigation and that the vehicle [384]*384is being used in the commission of a crime of stalking . . . The court ordered the following:
1. The State[']s request to install and monitor a tracking device on the below listed vehicle is granted based on the authority granted in [United States v. Karo, 468 U.S. 705 (1984)].
2. The Madison Police Department is authorized to place an electronic tracking device on a 1990 black Beretta with a license plate number of 754 ELL and a VIN of 1G1LZ14A2LY130646, and they are hereby authorized to surreptitiously enter and reenter the vehicle and any buildings and structures containing the vehicle or any premises on which the vehicle is located to install, use, maintain and conduct surveillance and monitoring of the location and movement of a mobile electronic tracking device in the vehicle and any and all places within or outside the jurisdiction of Iowa or Dane County, including but not limited to private residence and other locations not open to visual surveillance; to accomplish the installation, agents are authorized to obtain and use a key to operate and move the vehicle for a required time to a concealed location and are authorized to open the engine compartment and trunk areas of the vehicle to install the device.
3. It is further ordered that the Madison Police Department shall remove the electronic tracking device as soon as practicable after the objectives of the surveillance are accomplished or not later than 60 days from the date the order is signed unless extended by this court or another court of competent jurisdiction.
¶ 8. In the early morning hours of April 23, 2003, Ricksecker and three other law enforcement officers located Sveum's vehicle parked in the driveway of 2426 Valley Road, Cross Plains. A battery-powered GPS tracking device was attached to the "undercarriage" of Sveum's vehicle with magnetic equipment and tape. [385]*385The officers did not open the engine compartment or trunk area of the vehicle while installing the GPS. Because of the limited battery life of the GPS, the officers replaced the GPS twice. Both replacement devices were attached to Sveum's vehicle in the same manner in which the first was attached, i.e., to the undercarriage of the vehicle with magnetic equipment and tape while parked in the driveway of 2426 Valley Road, Cross Plains. The third and final GPS was removed from Sveum's vehicle on May 27, 2003.
¶ 9. Upon removal of the GPS devices, the stored information on each of the GPS devices was downloaded and then stored on a disk. The information from the disk was put on a map so the officers could see where Sveum's vehicle had traveled.
¶ 10. The GPS device revealed data incriminating Sveum. The GPS data indicated that on April 25, 2003, Sveum's vehicle traveled to a location 468 feet from Johnson's residence, and his vehicle remained there from 8:14 p.m. to 9:08 p.m. Sveum's vehicle then traveled to a shopping mall near Mineral Point Road and the Beltline Highway and remained there from 9:16 p.m. to 9:19 p.m. Phone records indicated that at 9:17 p.m. Johnson received a hang-up call from a pay phone located near the shopping mall where Sveum's vehicle was. Additionally, the GPS data demonstrated that on April 26, 2003, Sveum's vehicle traveled to a location 277 feet from Johnson's residence and remained there from 8:28 p.m. to 9:43 p.m.
¶ 11. Based, in part, on the above-described tracking data from the GPS devices, the police obtained two additional search warrants. One warrant authorized the police to search the premises located at 2426 Valley Road, Cross Plains and Sveum's vehicle. The search revealed evidence incriminating Sveum, including pho[386]*386tos of Johnson, a handwritten chronological log recording sightings of Johnson and letters sent to his sister, Renee Sveum, asking for information about Johnson. The other warrant authorized the police to search the premises located at 6685 County Trunk Highway K, Renee Sveum's residence, which did not reveal any incriminating evidence.
¶ 12. On August 4, 2003, the State filed a complaint charging Sveum4 with aggravated stalking as a party to a crime contrary to Wis. Stat. § 940.32(3)(b) (2001-02)5 and Wis. Stat. § 939.05 (2001-02). Sveum filed a motion to suppress all information obtained from the GPS device, arguing that it was unlawfully obtained in violation of the Fourth Amendment.6 The circuit court denied the motion on the grounds that installing and monitoring the GPS device was not a search. While the circuit court did not specifically address whether the court order authorizing police use of the GPS device was a warrant, it noted that the affidavit provided sufficient probable cause to obtain the order.
¶ 13. The case proceeded to trial where a jury found Sveum guilty of the charged offense. On February 6, 2007, the court entered a judgment of conviction and sentenced Sveum to seven years and six months in [387]*387prison followed by five years of extended supervision. Sveum filed a motion for post-conviction relief, seeking a new trial on various grounds, all of which the court rejected.
¶ 14. The court of appeals affirmed. State v. Sveum (Sveum II), 2009 WI App 81, ¶ 2, 319 Wis. 2d 498, 769 N.W.2d 53. The court of appeals addressed a number of issues not raised in this court. Id., ¶¶ 1-2. On the Fourth Amendment issue, the court of appeals concluded that installing and monitoring the GPS device on Sveum's vehicle did not constitute a search or a seizure within the meaning of the Fourth Amendment. Id., ¶ 6. As such, the court did not address whether the court order authorizing the installation and monitoring of the GPS device was a warrant. Id., ¶ 6 & n.3.
¶ 15. Sveum petitioned this court for review, which we granted. We now affirm the decision of the court of appeals.
II. STANDARD OF REVIEW
¶ 16. In reviewing the denial of a motion to suppress evidence, we will uphold a circuit court's findings of historical fact unless they are clearly erroneous. State v. Arias, 2008 WI 84, ¶ 12, 311 Wis. 2d 358, 752 N.W.2d 748. However, "[t]he question of whether police conduct violated the constitutional guarantee against unreasonable searches and seizures is a question of constitutional fact" that we review independently. Id., ¶ 11 (internal quotations and brackets omitted).
¶ 17. Whether the language of a court order satisfies the requisite constitutional requirements of a warrant is a question of law we review independently. See State v. Meyer, 216 Wis. 2d 729, 744, 576 N.W.2d 260 (1998).
[388]*388III. DISCUSSION
¶ 18. The Fourth Amendment of the United States Constitution guarantees that persons shall be secure from "unreasonable searches and seizures and sets forth the manner in which warrants shall issue." State v. Henderson, 2001 WI 97, ¶ 17, 245 Wis. 2d 345, 629 N.W.2d 613. The Fourth Amendment of the United States Constitution provides:
The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.7
A search and seizure conducted without a warrant issued pursuant to the requirements of the Fourth Amendment is presumptively unreasonable. Henderson, 245 Wis. 2d 345, ¶ 19.
[389]*389¶ 19. Whether a search and seizure pursuant to a warrant is constitutionally valid is a two-part inquiry. First, the Warrant Clause demands that all warrants be validly issued. Id. Second, the Reasonableness Clause requires that warrants be reasonably executed. Id., ¶ 18.
A. Warrant Clause
¶ 20. The "warrant clause provides [] particularized protections governing the manner in which search and arrest warrants are issued." Id., ¶ 19. The United States Supreme Court has interpreted the Warrant Clause to be " 'precise and clear,'" and as requiring only three things: (1) prior authorization by a neutral, detached magistrate; (2) a demonstration upon oath or affirmation that there is probable cause to believe that evidence sought will aid in a particular conviction for a particular offense; and (3) a particularized description of the place to be searched and items to be seized. Dalia v. United States, 441 U.S. 238, 255 (1979) (quoting Stanford v. Texas, 379 U.S. 476, 481 (1965)).
1. Neutral and detached magistrate
¶ 21. First, when officers obtain prior judicial authorization for a search, the magistrate who issues the warrant must be neutral and detached. Henderson, 245 Wis. 2d 345, ¶ 19 (citing Dalia, 441 U.S. at 255). This requirement protects citizens because " 'the usual inferences which reasonable men draw from evidence'" are " 'drawn by a neutral and detached magistrate instead of being judged by the officer engaged in the often competitive enterprise of ferreting out crime.'" State ex rel. White v. Simpson, 28 Wis. 2d 590, 597, 598, 137 N.W.2d [390]*390391 (1965) (quoting Johnson v. United States, 333 U.S. 10, 14 (1948) (concluding that "the determination of the district attorney does not constitute the determination of a neutral and detached magistrate")). We have explained that the purpose of this rule "is to interpose the impartial judgment of a judicial officer between the citizen and the police and also between the citizen and the prosecutor, so that an individual may be secure from an improper search." Id. at 598.
2. Probable cause
¶ 22. Second, "the officer seeking a warrant [must] demonstrate upon oath or affirmation probable cause to believe that 'the evidence sought will aid in a particular apprehension or conviction' for a particular offense." Henderson, 245 Wis. 2d 345, ¶ 19 (quoting Warden v. Hayden, 387 U.S. 294, 307 (1967)). "[W]hen no sworn testimony exists to support a search warrant, then the warrant is void." State v. Tye, 2001 WI 124, ¶ 13, 248 Wis. 2d 530, 636 N.W.2d 473 (citing State v. Baltes, 183 Wis. 545, 553, 198 N.W. 282 (1924)).
¶ 23. The Wisconsin constitutional oath or affirmation provision has been reinforced by legislation. Id., ¶ 11. A search warrant may be based either "upon sworn complaint or affidavit, or testimony recorded by a phonographic reporter," Wis. Stat. § 968.12(2), or "upon sworn oral testimony communicated to the judge by telephone, radio or other means of electronic communication," Wis. Stat. § 968.12(3)(a).
¶ 24. A search warrant may issue only on probable cause. State v. Higginbotham, 162 Wis. 2d 978, 989, 471 N.W.2d 24 (1991). The task of the issuing magis[391]*391trate is to determine whether, under the totality of the circumstances, given all the facts and circumstances set forth in the affidavit, " 'there is a fair probability that contraband or evidence of a crime will be found in a particular place.'" State v. DeSmidt, 155 Wis. 2d 119, 131, 454 N.W.2d 780 (1990) (quoting Illinois v. Gates, 462 U.S. 213, 238 (1983)). The probable cause standard is not a "technical, legalistic concept but a flexible, common-sense measure of the plausibility of particular conclusions about human behavior." State v. Petrone, 161 Wis. 2d 530, 547-48, 468 N.W.2d 676 (1991), overruled in part by State v. Greve, 2004 WI 69, 272 Wis. 2d 444, 681 N.W.2d 479 (citing Texas v. Brown, 460 U.S. 730, 743 (1983)).
¶ 25. "We accord great deference to the warrant-issuing judge's determination of probable cause and that determination will stand unless the defendant establishes that the facts are clearly insufficient to support a finding of probable cause." Higginbotham, 162 Wis. 2d at 989; see also Gates, 462 U.S. at 236. "The duty of the reviewing court is to ensure that the magistrate had a substantial basis for concluding that the probable cause existed." Higginbotham, 162 Wis. 2d at 989. Such determination is "confined to the record that was before the warrant-issuing judge." Id.
¶ 26. Our deferential review of the warrant-issuing judge's probable cause determination is " 'appropriate to further the Fourth Amendment's strong preference for searches conducted pursuant to a warrant.'" Id. at 990 (quoting Massachusetts v. Upton, 466 U.S. 727, 733 (1984) (further quotation omitted)). Accordingly, we resolve doubtful or marginal cases regarding a probable [392]*392cause finding in light of the Fourth Amendment's strong preference for searches conducted pursuant to a warrant. Id.
3. Particularity
¶ 27. Finally, the warrant clause requires "that warrants [] particularly describe the place to be searched, as well as the items to be seized." Henderson, 245 Wis. 2d 345, ¶ 19 (citing Dalia, 441 U.S. at 255). "In order to satisfy the particularity requirement, the warrant must enable the searcher to reasonably ascertain and identify the things which are authorized to be seized." State v. Noll, 116 Wis. 2d 443, 450-51, 343 N.W.2d 391 (1984). A general description of the items to be seized is constitutionally acceptable when a more specific description is not available. Id. at 451.
¶ 28. The particularity requirement fulfills three objectives. Petrone, 161 Wis. 2d at 540. It prevents general searches, the issuance of warrants on less than probable cause and the seizure of objects other than those described in the warrant. Id.
¶ 29. In United States v. Karo, 468 U.S. 705 (1984), the Court was called on to decide whether the warrantless monitoring of a "beeper," an electronic tracking device, in a private residence constituted a search within the meaning of the Fourth Amendment. Id. at 707. The Court concluded that monitoring the beeper in a private residence constituted a warrantless search. Id. at 714. In so concluding, the Court rejected the argument that a warrant should not be required to authorize the installation and monitoring of electronic [393]*393tracking devices "because of the difficulty in satisfying the particularity requirement of the Fourth Amendment." Id. at 718.
¶ 30. Specifically, the "Government contended] that it would be impossible to describe the 'place' to be searched, because the location of the place is precisely what is sought to be discovered through the search." Id. The Court explained that a warrant application that "describe[s] the object into which the [tracking device] is to be placed, the circumstances that led agents to wish to install the [tracking device], and the length of time for which [] surveillance is requested" is sufficient to satisfy the constitution's particularity requirement and will "permit issuance of a warrant authorizing [] installation [of a tracking device] and surveillance." Id.
4. Severability doctrine
¶ 31. In the event of a constitutionally defective search warrant, we may apply the exclusionary rule,8 which bars all evidence obtained pursuant to the defective warrant from a criminal proceeding against the defendant whose constitutional rights have been violated. See State v. Ward, 2000 WI 3, ¶ 46, 231 Wis. 2d 723, 604 N.W.2d 517. However, in Noll, we addressed the issue of the appropriate remedy for items seized pursuant to a partially defective search warrant. Noll, 116 Wis. 2d at 451.
¶ 32. In Noll, we concluded that a search warrant authorizing the seizure of "various long play phono[394]*394graph albums, and miscellaneous vases and glassware items" lacked the required particularity; however, the remaining items described in the warrant were "sufficiently particular to satisfy the constitutional requirement." Id. at 451. As such, the search warrant was defective only with respect to those items that were seized, but inadequately described.
¶ 33. We recognized the harshness of applying the exclusionary rule to search warrants that are partially defective. Quoting Professor LaFave, we explained: " '[I]t would be harsh medicine indeed if a warrant which was issued on probable cause and which did particularly describe certain items were to be invalidated in toto merely because the affiant and magistrate erred in seeking and permitting a search for other items as well.'" Id. at 454 (quoting 2 Wayne R. LaFave, Search and Seizure § 4.6(f) (1978)). Indeed, we farther noted that such a rule would "unduly hamper[] the government's efforts to gather evidence of crime and is not compelled by the purposes underlying the exclusionary rule." Id. at 460.
¶ 34. To avoid such harsh results, we adopted the "severability doctrine," which permits reviewing courts to excise the defective portions of an otherwise valid warrant. Id. at 445.9 We explained that "admitting those [395]*395items seized pursuant to the valid parts of the warrant and suppressing those items seized" under the defective portion, "strike[s] the proper balance between the government's obligation to enforce its laws to protect its citizens from wrongdoers and the citizen's right to be secure... from unreasonable government intrusion[s]." Id. at 454.
¶ 35. We concluded that application of the sever-ability doctrine was proper, and therefore, we excised the defective warrant provisions from the valid warrant provisions. The items seized pursuant to the valid portion of the warrant were admitted, and those items seized pursuant to the defective portion were suppressed. See id.
¶ 36. The court of appeals applied the severability doctrine to a search warrant in State v. Marten, 165 Wis. 2d 70, 477 N.W.2d 304 (Ct. App. 1991). In Marten, a search warrant authorized police to search a "home, yard and 'outbuildings'" for drug paraphernalia based on information provided by an informant and through police officer surveillance. Id. at 72-73. While executing the search warrant, officers seized marijuana found in Marten's house. Marten filed a motion to suppress all the evidence resulting from the execution of the search warrant arguing, among other things, that the warrant was fatally overbroad because there was not probable cause to support a search of Marten's house, yard or outbuildings. Id. at 76.
¶ 37. The court concluded that the complaint established probable cause to believe that marijuana would be found in Marten's home. Id. at 75. The court declined to decide whether the warrant established probable cause to search the yard and outbuildings because "there [was] no evidence that these areas were ever searched" and no evidence was found in them. Id. [396]*396at 77. Noting that the severability rule applies to situations in which "a warrant's description of the property to be seized is overly broad" and "the seizure of items under an appropriately specific warrant was overly broad," the court concluded that the severability rule "applies equally where the description of the premises to be searched is overly broad." Id. at 77 (citing Noll, 116 Wis. 2d at 454-55; Petrone, 161 Wis. 2d at 548). Accordingly, the portion of the warrant authorizing a search of the yard and outbuildings was severed from the valid portion authorizing the search of Marten's home. The drugs were admissible as they were seized from Marten's home pursuant to the valid portion of the warrant. Id.
¶ 38. Similarly, the United States Court of Appeals for the Third Circuit has stated: An overly broad warrant that authorizes searches for which there is no probable cause, "can be cured by redaction, that is, by 'striking from [the] warrant those severable phrases and clauses that are invalid for lack of probable cause or generality and preserving those severable phrases and clauses that satisfy the Fourth Amendment.'" United States v. Ninety-Two Thousand Four Hundred Twenty-Two Dollars and Fifty-Seven Cents ($92,422.57), 307 F.3d 137, 149 (3d Cir. 2002) (quoting United States v. Christine, 687 F.2d 749, 754 (3d Cir. 1982)).
5. Application
¶ 39. We conclude that the order authorizing the installation and monitoring of a GPS tracking device on Sveum's vehicle was a valid search warrant under the Fourth Amendment. First, the order was signed by a neutral and detached magistrate. Second, Ricksecker's [397]*397affidavit provided probable cause for the portion of the order authorizing law enforcement to "install, use, [and] maintain" a GPS tracking device on Sveum's vehicle and to subsequently "remove" such device. Assuming, arguendo, that the portions of the order granting law enforcement broader authority to search, i.e., authorization to search "any buildings and structures containing the vehicle," are invalid because the affidavit failed to demonstrate probable cause to search such areas, we sever those portions from the order. Finally, the order particularly described the object into which the GPS was to be placed, i.e., Sveum's vehicle; the circumstances that led agents to seek to install the GPS, i.e., evidence of Sveum's stalking activities; and the length of time for which GPS surveillance was requested, i.e., no more than 60 days. See Karo, 468 U.S. at 718.
¶ 40. Sveum contends that because the State's only argument in the circuit court was that no search warrant was required because the officers' committed no search or seizure, "the [S]tate well may have waived the argument that the court order here was a search warrant." We exercise our discretion to reach this issue, rather than deem it waived. See Umansky v. ABC Ins. Co., 2009 WI 82, ¶ 23 & n.17, 319 Wis. 2d 622, 769 N.W.2d 1 ("The rule of waiver is one of judicial administration and does not limit the power of an appellate court in a proper case to address issues not raised in the circuit court.") (citing State v. Caban, 210 Wis. 2d 597, 609, 563 N.W.2d 501 (1997)). Therefore, we turn to the merits of this issue.
¶ 41. We first examine whether the order here represents "prior judicial authorization for a search [by] a neutral, disinterested magistrate." Henderson, 245 Wis. 2d 345, ¶ 19. We conclude that it does. The order, [398]*398signed by Judge Richard Callaway on April 22, 2003, authorized the Madison Police Department to install and monitor a GPS device on Sveum's vehicle. The officers attached the device after the order was issued. Accordingly, the order is prior judicial authorization from a neutral and detached magistrate.
¶ 42. Second, we examine whether Ricksecker "demonstrate^] upon oath or affirmation probable cause to believe that the evidence sought will aid in a particular apprehension or conviction for a particular offense." Id., ¶ 19 (internal quotations omitted). We conclude that it does.
¶ 43. Affording Judge Callaway's probable cause determination great deference, we conclude that he had a substantial basis for concluding that given all the facts and circumstances set forth in Ricksecker's ample and detailed affidavit, there was a fair probability that installing and monitoring a GPS tracking device on Sveum's vehicle would produce evidence of stalking. Accordingly, we sustain Judge Callaway's determination that the order was supported by probable cause authorizing law enforcement to "install, use, [and] maintain" a GPS tracking device on Sveum's vehicle and to subsequently "remove" such device.
¶ 44. Ricksecker's affidavit, sworn on "oath or affirmation," demonstrated that the GPS data sought probably would provide evidence of Sveum's stalking Johnson. See id., ¶ 19; Wis. Stat. § 968.12(2). The affidavit established Ricksecker's significant training, experience and knowledge in investigating stalking cases and that such experience led her to believe that GPS tracking devices are "successful supplements] to visual surveillance" as it "lessens the risk of visual detection by the suspect" and "is generally considered more reliable" than attempted visual surveillance.
[399]*399¶ 45. Ricksecker also averred, in significant detail, to her lengthy history investigating Sveum. She was aware of the facts of Sveum's two previous convictions for violating a domestic abuse order, both involving Johnson. She personally investigated Sveum's previous case that resulted in a conviction of stalking also involving Johnson. As such, Ricksecker was personally familiar with Sveum's criminal pattern of targeting Johnson as a victim.
¶ 46. The affiant averred that Johnson reported receiving nine hang-up phone calls between March 3, 2003, and April 12, 2003. Johnson's allegation was confirmed by TDS Metrocom phone records and the Dane County 911 Dispatch Center. The phone records indicated that each of the hang-up calls came from various pay phones in Dane County. Significantly, the affidavit established that the hang-up calls Johnson reported were consistent with Sveum's stalking behavior from his previous conviction, which was "based on hang-up calls received by Jamie Johnson at her residence."
¶ 47. The affiant established through investigation and Department of Transportation records the make, model, license plate number and VIN of Sveum's vehicle.
¶ 48. Finally, the affiant explained that the GPS device had limited battery power. Accordingly, it was necessary to periodically change the battery of the GPS device to maintain it for extended surveillance.
¶ 49. The foregoing evidence established a "fair probability" that Sveum was using his vehicle to stalk Johnson and that tracking the location of Sveum's vehicle by installing and maintaining a GPS tracking device would produce evidence of the crime of stalking. See DeSmidt, 155 Wis. 2d at 131.
[400]*400¶ 50. Sveum argues that the order's description of the premises law enforcement may search is not supported by probable cause and therefore is impermissibly overbroad. Specifically, he argues that Ricksecker's affidavit failed to demonstrate probable cause to "surreptitiously enter and reenter the vehicle and any buildings and structures containing the vehicle or any premises on which the vehicle is located . .. including but not limited to private residence and other locations not open to visual surveillance," to "obtain and use a key to operate and move the vehicle" and to "open the engine compartment and trunk areas of the vehicle."10
¶ 51. Because "there is no evidence that these areas were ever searched, and it does not appear that any evidence was found in them," we assume, without deciding, that the portions of the warrant Sveum points to above are not supported by probable cause and therefore are impermissibly overbroad. Marten, 165 Wis. 2d at 77. The proper remedy for the partially defective order is to "strik[e] from [the] warrant those severable phrases and clauses that are invalid for lack of probable cause." $92,422.57, 307 F.3d at 149 (internal quotations omitted). Accordingly, we strike the portions of the order that we assume, arguendo, are defective. However, the other portions of the order remain. Noll, 116 Wis. 2d at 445. As we concluded above, the portion of the order that authorized law enforcement to "install, use, [and] maintain" a GPS tracking device on Sveum's vehicle and to subsequently "remove" such device is valid. See supra ¶ 49.
[401]*401¶ 52. Finally, we examine whether the order "particularly describe[d] the place to be searched." Henderson, 245 Wis. 2d 345, ¶ 19. We conclude that Ricksecker's affidavit meets the particularity requirements with respect to electronic tracking devices as explained in Karo, 468 U.S. 705. First, the affiant explained that Sveum's vehicle, identified by make, model, license plate and VIN, was the "object into which the [GPS device was] to be placed." Id. at 718. Second, the affiant described the "circumstances that led agents to wish to install the [GPS device]." Id. The affiant explained that Sveum had previously been convicted of stalking Johnson. Such conviction was "based on hang-up calls received by Jamie Johnson at her residence." It was further alleged that the hang-up calls ceased upon Sveum's incarceration, and commenced again after Sveum was released from incarceration. The hang-up calls were verified by TDS Metrocom phone records. It was these circumstances that led Ricksecker to believe that Sveum's vehicle was "being utilized in the commission of. . . stalking" and that "installation of a [GPS] tracking device on [Sveum's] vehicle in conjunction with the monitoring, maintenance and retrieval of information from that [GPS] tracking device will lead to evidence of [stalking]." Finally, Ricksecker requested authorization to monitor the GPS device "for a period of time not to exceed 60 days." The order generally reiterated such information. Accordingly, we conclude that such information "suffice[s] to permit issuance of a warrant authorizing [GPS] installation and surveillance" on Sveum's vehicle. Id.
[402]*402B. Reasonableness Clause
¶ 53. Even if a court determines that a search warrant is constitutionally valid, the manner in which the warrant was executed remains subject to judicial review. See State v. Andrews, 201 Wis. 2d 383, 390, 549 N.W.2d 210 (1996). "A search 'must be conducted reasonably and appropriately limited to the scope permitted by the warrant.'" Id. (quoting Petrone, 161 Wis. 2d at 542). "[I]t is generally left to the discretion of the executing officers to determine the details of how best to proceed with the performance of a search authorized by the warrant — subject of course to the general Fourth Amendment protection 'against unreasonable searches and seizures.'" Dalia, 441 U.S. at 257.
¶ 54. "There is no formula for the determination of reasonableness." Ker v. California, 374 U.S. 23, 33 (1963) (internal citations omitted). Whether a search was reasonable depends on the particular circumstances of the case and requires a balancing of " 'the nature and quality of the intrusion on the individual's Fourth Amendment interests against the importance of the governmental interests alleged to justify the intrusion.' " Henderson, 245 Wis. 2d 345, ¶ 18 (quoting United States v. Place, 462 U.S. 696, 703 (1983) (further quotation omitted)). Constitutional reasonableness relates to the grounds for the search and seizure and to the circumstances surrounding the execution of the search. Id.
¶ 55. Whether a search was reasonably ordered and executed is further informed by the Wisconsin Statutes. For example, Wis. Stat. § 968.12(1) defines the parameters of a search warrant. Section 968.12 codifies [403]*403the Warrant Clause's requirements and provides part of the framework for a circuit court's action; § 968.12(1) provides:
A search warrant is an order signed by a judge directing a law enforcement officer to conduct a search of a designated person, a designated object or a designated place for the purpose of seizing designated property or kinds of property. A judge shall issue a search warrant if probable cause is shown.
¶ 56. Wisconsin Stat. § 968.12(1) establishes that to constitute a search warrant as described in the statute, the order must be signed by a judge (a neutral and detached magistrate), must particularly describe the place to be searched and the items to be seized and must be supported by probable cause. We concluded that the order here met each of these requirements. See supra Part III.A.5. An order meeting the parameters of a search warrant set out in this section is a statutorily authorized warrant, even though the document is entitled "order." Therefore, that the order in this case was not entitled, "search warrant," does not affect its validity because, as the statute clearly states, "[a] search warrant is an order." § 968.12(1).
¶ 57. A violation of a Wisconsin statute relating to search warrants does not necessarily lead to the conclusion that a search that was conducted is unreasonable. See, e.g., State v. Meier, 60 Wis. 2d 452, 459-60, 210 N.W.2d 685 (1973) (concluding that any error as to the return of the search warrant violating Wis. Stat. § 968.17 did not prejudice the rights of the defendant and therefore did not affect the validity of the search). [404]*404Case law and Wis. Stat. § 968.2211 provide that "evidence must not be suppressed for a mere statutory violation or a technical irregularity of search warrant procedure unless the violation or irregularity is material or the violation or irregularity has prejudiced the defendant or affected the defendant's substantial rights." State v. Popenhagen, 2008 WI 55, ¶ 126, 309 Wis. 2d 601, 749 N.W.2d 611 (Prosser, J., concurring). "Conversely, if a statutory violation or statutory irregularity of search warrant procedure is material or if the violation or irregularity has prejudiced the defendant or affected the defendant's substantial rights, the court has implicit, if not explicit, statutory authority to suppress the tainted evidence." Id. (citing § 968.22).
¶ 58. We conclude that in light of the facts and circumstances in this case, the order constitutes a valid search warrant.12 It was reasonably executed because the search was "conducted reasonably and [was] appropriately limited to the scope permitted by the warrant." Andrews, 201 Wis. 2d at 390 (internal quotation omitted). Further, violations of the Wisconsin statutes gov[405]*405erning search warrants were mere "technical irregularities," Wis. Stat. § 968.22, that did not render the search unreasonable. Accordingly, the data seized from the GPS device was not subject to suppression.
¶ 59. The officers entered the driveway to install the GPS device in Sveum's vehicle. Installation was achieved simply, by attaching the device with magnets and tape to the vehicle's undercarriage. Maintenance of the GPS device included replacing the device twice, due to its limited battery life. Both replacement devices were installed in the same manner as the first. After monitoring Sveum's vehicle for 35 days, the officers removed the GPS device. Execution in this manner stayed well within the confines of the authority granted by the order, which authorized law enforcement to "install, use, [and] maintain" a GPS tracking device on Sveum's vehicle and to subsequently "remove" such device.
¶ 60. Additionally, "[t]here is no indication that [law enforcement's] intrusion went beyond what was necessary to install and remove the equipment." Dalia, 441 U.S. at 258 n.20. Indeed, the officers did not enter any building, including Sveum's home, nor did they access the passenger compartment or the trunk of the vehicle during installation, maintenance and removal of the GPS device. Additionally, the officers replaced the GPS devices only as was necessary and in the same minimally intrusive manner as the initial installation.
¶ 61. Sveum raises several arguments, which he contends demonstrate that the order was not reasonably executed. Specifically, Sveum argues that the officers violated his Fourth Amendment rights by: (1) failing to provide him notice of the order issued by the circuit court prior to executing it; (2) performing a search that [406]*406exceeded the scope of the order; and (3) failing to comply with the statutory return and inventory procedures. We disagree.
¶ 62. The Supreme Court has specifically noted the "absence of a constitutional requirement that the warrant be exhibited at the outset of the search." United States v. Grubbs, 547 U.S. 90, 99 (2006) (internal quotation omitted); see also Groh v. Ramirez, 540 U.S. 551, 562 n.5 (2004). The Groh Court explained the reasoning for the absence of such a requirement. It explained: "Quite obviously, in some circumstances — a surreptitious search by means of a wiretap, for example, or the search of empty or abandoned premises — it will be impracticable or imprudent for the officers to show the warrant in advance." Groh, 540 U.S. at 562 n.5.
¶ 63. Groh's reasoning squarely applies here. Quite obviously, installing and monitoring the GPS tracking device without Sveum's knowledge was crucial to obtaining evidence demonstrating Sveum was using his vehicle to stalk Johnson.
¶ 64. As stated, Sveum also argues that the officers search exceeded the scope of the order. He argues this is so because each day the officers monitored Sveum's vehicle using the GPS device constituted a separate intrusion requiring a new search warrant. Again, we disagree.
¶ 65. In United States v. Squillacote, 221 F.3d 542 (4th Cir. 2000), the United States Court of Appeals for the Fourth Circuit rejected an argument similar to Sveum's. In Squillacote, pursuant to an investigation of suspected "espionage-related activities," a search warrant was issued authorizing the search of the defendants' home for a period of not more than 10 days. Id. at 557, 554. The search extended over six days. Id. at 557. The defendants argued that the evidence seized pursu[407]*407ant to the warrant "must [j be suppressed because the government did not obtain a new warrant for each successive day of searching." Id.
¶ 66. The court rejected this argument reasoning that due to the complex, ongoing nature of the espionage-related activities and the nature of the evidence sought "the search was necessarily extensive and exhaustive." Id. Because "the search could not have been completed in a single day" and because it viewed "the subsequent entries [] not [as] separate searches requiring separate warrants, but instead [as] [] reasonable continuations of the original search" the government was not required to obtain additional warrants for each day the search continued. Id.
¶ 67. We similarly conclude that the complex, ongoing nature of stalking justified the 35 days of GPS surveillance on a single search warrant. See Wis. Stat. § 940.32(l)(a), (2)(c) (2001-02) (stalking requires, inter alia, a "course of conduct," which is "a series of 2 or more acts carried out over time ... that show a continuity of purpose," directed at a specific person inducing fear of bodily injury or death); Wis. Stat. § 940.32(3)(b) (2001-02) (requiring a violation of sub. (2) and a previous stalking conviction of the same victim within seven years for the commission of aggravated stalking). Evidence sufficient to demonstrate Sveum's stalking required, inter alia, data demonstrating Sveum engaged in "a series of 2 or more acts carried out over time," inducing Johnson to fear bodily injury or death. See § 940.32(l)(a), (2)(c). A search obtaining this type of evidence could not have been completed in a single day. Moreover, the daily, continuous monitoring of the GPS device on Sveum's vehicle "were not separate searches requiring separate warrants, but instead were simply [408]*408reasonable continuations of the original search." Squillacote, 221 F.3d at 557. Accordingly, the officers were not required to obtain additional search warrants for each day the GPS monitoring continued.
¶ 68. Wisconsin Stat. § 968.15 requires a search warrant to be "executed and returned not more than 5 days after the date of issuance." Wisconsin Stat. § 968.17(1) requires that a search warrant be returned to the clerk of court "within 48 hours after execution" and that such return "be accompanied by a written inventory of any property taken." The requirement of a prompt return and inventory" 'safeguard[s] [] the property rights of individuals'" by ensuring that defendants are not permanently deprived of having access to and control over their property seized pursuant to a search warrant. See Meier, 60 Wis. 2d at 459 (quoting 68 Am Jur. 2d Searches and Seizures § 83, at 738).
¶ 69. The order in this case was not returned along with a written inventory to the circuit court. See Wis. Stat. §§ 968.15 & 968.17. Law enforcement's failure to return the order and inventory within the confines of §§ 968.15 and 968.17 do not render the execution of the order unreasonable. The timely return of a warrant is "a ministerial duty which [does] not affect the validity of the search absent prejudice to the defendant." State v. Elam, 68 Wis. 2d 614, 620, 229 N.W.2d 664 (1975) (citing Meier, 60 Wis. 2d 452); accord 2 Wayne R. LaFave, Search and Seizure § 4.12(c) (4th ed. 2004) ("[T]he 'overwhelming weight of authority' is to the effect that required warrant return procedures are ministerial and that failure to comply with them is not a ground for voiding an otherwise valid search.") (quoting United States v. Kennedy, 457 F.2d 63, 67 (10th Cir. 1972)).
[409]*409¶ 70. Sveum has failed to demonstrate that he was prejudiced by law enforcement's failure to comply with the procedural return statutes. Because the officers in this case did not seize any tangible evidence, but instead intangible electronic data, there was no property to be returned to Sveum and, therefore, no property to safeguard prior to its return to Sveum. Moreover, at all times Sveum had access to and control over the location of his vehicle.
¶ 71. Similarly, we are not persuaded that Sveum's substantial rights were violated by the officers' failure to execute and return the warrant within 5 days after the date of issuance. See Wis. Stat. § 968.15. We note that under the Federal Rules of Criminal Procedure, which explicitly govern warrants for tracking devices, officers may use a tracking device for a period not more than "45 days from the date the warrant was issued." Fed. R. Crim. E 41(e)(2)(C).13 As the United States Supreme Court has explained, "Federal Rule of Criminal Procedure 41 [] reflects the Fourth Amendment's policy against unreasonable searches and seizures." Zurcher v. Stanford Daily, 436 U.S. 547, 558 (1978) (internal quotation and brackets omitted). Here, the officers removed the GPS tracking device 35 days from the date the order was issued. As we have explained, the officers' use of the GPS device for 35 days was reasonable and, therefore, the lack of a return to the circuit court in five days did not violate Sveum's substantial rights.
¶ 72. Accordingly, because we conclude that the failure to comply with the requirements of Wis. Stat. §§ 968.15 and 968.17 did not prejudice Sveum's sub[410]*410stantial rights, the effect of the error is cabined by Wis. Stat. § 968.22. Section 968.22 provides that unless an error in the warrant affects a substantial right of the defendant, the error does not permit the suppression of evidence. Therefore, suppression of the evidence obtained here is not permissible. See Popenhagen, 309 Wis. 2d 601, ¶ 126 (Prosser, J., concurring); § 968.22.
IV CONCLUSION
¶ 73. Sveum and the State have briefed two issues for purposes of our review: (1) whether the installation of a GPS tracking device to Sveum's car while his car was parked in the driveway of his home and the subsequent electronic monitoring of Sveum's car using the GPS constituted a search or seizure within the meaning of the Fourth Amendment of the United States Constitution and Article I, Section 11 of the Wisconsin Constitution; and (2) whether the court order authorizing the installation and monitoring of a GPS tracking device on Sveum's vehicle constituted a valid warrant and, if so, whether the police reasonably executed the warrant.
¶ 74. We elect not to resolve the first issue, and assume, without deciding, that a search or seizure occurred in this case that required authorization by a warrant. We therefore decide only the second issue, concluding that the order authorizing law enforcement to install and monitor a GPS tracking device on Sveum's vehicle constituted a valid warrant and that the officers' execution of the warrant was reasonable. Accordingly, we affirm the decision of the court of appeals.
By the Court. — The decision of the court of appeals is affirmed.