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I call BS on this one. The phones need proper GPS reception for this to work and the ones in the deeper layers of the cart will not have that. Furthermore Google will probably filter out cases like "99 phones on a single spot". They need to filter out pedestrian traffic anyways.
That's maybe why using the cart, so that it doesn't have the step-shaking, but smoother movement. And I don't think the upper devices will block the GPS signal too much.
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Accelerometer sensor data for a cart rolling down a street is very different than a car. Google can certainly tell the difference. It is in the Android API. The only question is whether they bother with the extra processing, as it is only a few minutes * tens of meters noise.
I think it’s more likely that they’re using the cart because nobody has pocket space for 99 phones.
Excellent point 
Also GPS signal on phones is only good down to 5m usually. Not saying that there could be some algorithm to sort out 99 phones in a small space like that though.
I cannot agree with you. I have been doing a lot of walking lately and all with Google maps, exploring routes I did not know, and I find GPS on my phone to be accurate to about 1m.
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