The Katz V

The Katz v.United States (1967) case,while shifting the Fourth Amendment inquiry from property rights to privacy rights,did not result in a lot of reversals of previously decided cases.Why were there not a lot of reversals following the decision?

A) privacy protection requires a reference to "place"
B) a change in focus applies only to future cases and no reversals can occur
C) no cases have come before the court requiring a reversal
D) a reversal would require a constitutional amendment