Chatrie v. United States
2026 United States Supreme Court case
From Wikipedia, the free encyclopedia
Chatrie v. United States (No. 25-112)[1] is a United States Supreme Court case in which the court held that a geofence warrant is a search subject to the Fourth Amendment.[2] Chatrie reaffirmed and expanded the Court's holding in the landmark 2018 case Carpenter v. United States.
| Chatrie v. United States | |
|---|---|
 | |
| Argued April 27, 2026 Decided June 29, 2026 | |
| Full case name | Okello T. Chatrie, Petitioner v. United States |
| Docket no. | 25-112 |
| Citations | 609 U.S. ___ (more) |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior |
|
| Questions presented | |
| 1. Whether the execution of the geofence warrant violated the Fourth Amendment. 2. Whether the exclusionary rule should apply to the evidence derived from the geofence warrant. | |
| Holding | |
| Police officers conducted a Fourth Amendment search when they acquired Chatrie’s location data from Google because an individual has a reasonable expectation of privacy in his cell-phone location information. Note: The Court remanded on whether the good-faith exception to the exclusionary rule should apply. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kagan, joined by Roberts, Sotomayor, Kavanaugh, Jackson |
| Concurrence | Jackson, joined by Sotomayor |
| Concurrence | Gorsuch (in judgment) |
| Dissent | Alito, joined by Thomas (as to Part I); Barrett (as to Parts II–B, II–C–1, and II–C–2) |
| Dissent | Barrett |
| Laws applied | |
| U.S. Const. amend. IV | |
Background
A geofence warrant is a law enforcement technique used to identify all persons present within a physical area at a particular time, and is a form of reverse search. The warrant utilizes technology companies' practice of collecting granular user location information. The law enforcement agency seeking the warrant will direct it toward a technology company, and identify a "geofence" (a virtual "fence" around a geographic location) along with a specific period of time.[3][4]
Before Carpenter, third-party data was not protected by the Fourth Amendment's warrant requirement under a legal theory known as the third-party doctrine. In 2018, Carpenter created a narrow exception to the third-party doctrine for Cell Site Location Information (CSLI), a particular type of location data collected by wireless carriers when a phone connects to a cell tower.[5] While CSLI can provide precise location information in places with many cell towers close together, geofence data is generally far more precise. Unlike CSLI, geofence data uses GPS pings, as well as Wi-Fi and Bluetooth connections. Additionally, in Carpenter, the government sought access to over 12,898 data points spanning 129 days.[6] In Chatrie, the geofence warrant covered 2 hours worth of location information.[1]
Lower court history
On May 20, 2019, a bank was robbed in Midlothian, Virginia. Over the coming weeks, the investigation would stall. On June 14, local law enforcement applied for and received a geofence warrant directed at Google. The "geofence" was a circle, centered at the bank, with a radius of 150 meters.[7]
The Government worked with Google to create a three-step process used for responding to such warrants. First, the warrant requests anonymized information on all user accounts within the geofence between 4:20pm and 5:20pm on the day of the robbery. Second, after reviewing such information, law enforcement would attempt to narrow down their list of possible suspects. They would then return to Google and seek non-geographically limited information on users from the narrowed list, between 3:50pm and 5:50pm (i.e., for an additional 30 minutes on each end of the original time period). Finally, after reviewing the second batch of information, law enforcement would again narrow the list of persons of interest, and return to Google, at which point the remaining accounts would be linked to identifiable users.[7]
Detective Joshua Hylton sent the geofence warrant to Google, which executed the first step of the process. In doing so, it returned anonymized data for 19 users within the geofence. Hylton subsequently requested an extra hour of location data, unbounded by the geofence, on nine users. Lastly, he requested de-anonymized information on three users, which Google supplied. Petitioner, Okello Chatrie, was among the three final users.[7]
Chatrie was indicted in the United States District Court for the Eastern District of Virginia on robbery and firearms charges. He moved to suppress the results of the geofence warrant. After extensive fact-finding, the district court declined to suppress the results of the warrant. Despite finding that the warrant violated the particularity and probable cause requirements of the Fourth Amendment, the court found that the evidence was nevertheless admissible under the good-faith exception to the exclusionary rule and denied the motion. Chatrie entered a conditional plea of guilty, reserving his right to appeal the denial of his motion to suppress.[7]
Court of Appeals
A divided panel of the Fourth Circuit affirmed. Dissenting, Judge Wynn concluded that the government violated petitioner's reasonable expectation of privacy. On rehearing en banc, the Fourth Circuit affirmed the district court's judgment in a one-sentence per curiam opinion.[8]
The 15–member court divided 7–7 on whether a Fourth Amendment search had occurred, with Chief Judge Diaz not expressing a view either way.[9] Seven judges concluded, in an opinion written by Judge Richardson, that no Fourth Amendment search occurred because petitioner lacked a “reasonable expectation of privacy in two hours’ worth of Location History data voluntarily exposed to Google,” with three judges within that group (Judges Wilkinson, Niemeyer, and King) filing separate concurrences. Seven judges, in an opinion written by Judge Wynn, concluded that a Fourth Amendment search had occurred. They reasoned that the government had “invaded [petitioner’s] reasonable expectation of privacy” in accessing his data, an expectation that the third-party doctrine was “wholly inadequate” to defeat. Of the seven judges who found a Fourth Amendment search, five concluded that the government's warrant application was not supported by probable cause, with two not opining on the issue. However, only Judge Gregory would have suppressed the evidence. The other six indicated that suppression was unwarranted under the good-faith exception.[7][10]
Supreme Court
On July 28, 2025, Chatrie petitioned the Supreme Court for a writ of certiorari. On January 16, 2026, the Court granted review. Oral arguments were heard on April 27, 2026. The case was argued by Adam Unikowsky (on behalf of Chatrie) and Eric Feigin (on behalf of the United States).[11]
On June 29, 2026, the Supreme Court held that the police conducted a Fourth Amendment search when they obtained Chatrie's location information from Google, because individuals have reasonable expectations of privacy in their cell phone location information.[12] The court did not hold that geofence warrants are unconstitutional.[1]