Canopy. The satellite transmitters are only about 50W, and even the closest ones are over 20,000km away.
If it's an 'H' type GPS it will pick up and use reflected signals, which will generate false positions (but still better than nothing, the theory goes). If a signal takes an extra 50 nanoseconds to arrive, the GPS will think its about 15m further away from that particular satellite, than it really is. 50ns is about the limit of accuracy of the leisure GPS system. For comparison, the Chilean earthquake changed the length of a day by about 1260ns.
The shape of the constellation changes surprisingly rapidly so the relative strengths of the reflected signals may also change, if a different set of 3 or 4 is prioritised the resulting calculation (which involves bogglingly large and ridiculously small numbers) will give a different result.