A woman who received 15 parking tickets in the last 3 years SUED - arguing that putting chalk on her private vehicle was the same as an unreasonable search - and a panel of 3 judges (eventually) agreed
From NBC News:
Taylor argued that marking tires with chalk constituted an unreasonable search under the Fourth Amendment to the Constitution. But a U.S. district judge in Michigan dismissed the suit in 2017, writing that even if chalking a tire is a search, it's a reasonable one, because a piece of chalk isn't an "information-gathering device" that could violate Taylor's privacy, like a GPS tracker, for example.
The appeals panel Monday agreed that chalking a tire is a search. But the judges disagreed that it was a reasonable search.