Chatrie v. United States
Key claim: Police must now obtain a constitutionally valid warrant before compelling Google (or similar services) to hand over users’ precise location history data, meaning geofence warrants that sweep up bystanders’ movements are subject to full Fourth Amendment scrutiny.
Abstract
U.S. Supreme Court opinion decided 2026-06-29, by Elana Kagan. (Slip Opinion) OCTOBER TERM, 2025 1
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CHATRIE v. UNITED STATES
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 25–112. Argued April 27, 2026—Decided June 29, 2026
On May 20, 2019, a man robbed a credit union in Midlothian, Virginia. Local police officers learned from witness interviews and surveillance footage that the robber had approached the credit union from a corner of an adjacent church while appearing to talk on a cell phone, but they could not find out anything more, and the robber remained at large. On June 14, the police officers applied to a Virginia magistrate for a geofence warrant directed to Google, which would require Google to hand over data about the cell phones located within a 150-meter radius of the credit union—the so-called “geofence”—near the time of the crime. The application described the cell-phone location data Google collects through a service called Location History, which records the location of a user’s cell phone every two minutes or so. The application also explained how that cell-phone location data could help identify the robber, possible accomplices, or additional witnesses. The warrant de- scribed a three-step process that the police would follow: at step one, Google would produce anonymized location data for all cell phones within the geofence 30 minutes before to 30 minutes after the robbery; at step two, officers would attempt to narrow the list, and Google would provide additional anonymized data for that narrowed list, consisting of cell-phone locations both inside and outside the geofence during a two-hour period surrounding the robbery; and at step three, officers would further narrow the list, and Google would turn over identifying information, including names and phone numbers, for users on the fi- nal list. The magistrate issued the warrant, and through this process, Google ultimately produced three cell-phone users’ identifying infor- mation, including petitioner Okello Chatrie, whose location data showed that he entered the geofence about ten minutes before the rob- bery and headed toward a residential area immediately after leaving 2 CHATRIE v. UNITED STATES
Syllabus
the bank.
Following further police work, a federal grand jury charged Chatrie
with robbery and related firearms offenses, and he moved to suppress
the information the police obtained from Google. According to Chatrie,
the officers had acquired that data through a Fourth Amendment
search, and the warrant ostensibly authorizing that search was inva-
lid. The District Court found that the geofence warrant “plainly vio-
lates the rights enshrined in [the Fourth] Amendment” but denied the
motion based on the good-faith exception to the exclusionary rule. 590
F. Supp. 3d 901, 905, 937–938. A divided panel of the Fourth Circuit
affirmed on different reasoning, holding that no search occurred be-
cause Chatrie “did not have a reasonable expectation of privacy in two
hours’ worth of Location History data voluntarily exposed to Google.”
107 F. 4th 319, 325. The Fourth Circuit granted rehearing en banc
and affirmed in a one-sentence per curiam, with the court dividing
evenly on whether a Fourth Amendment search had occurred. This
Court granted certiorari solely on the question whether the police vio-
lated the Fourth Amendment in obtaining Chatrie’s location data.
Held: 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 infor- mation. Pp. 10–33. (a) The Fourth Amendment protects individuals’ reasonable expec- tations of privacy, and governmental “intrusion into that private sphere generally qualifies as a search.” Carpenter v. United States, 585 U. S. 296, 304. The Amendment’s “basic purpose” is “to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials,” id., at 303, and it was designed “to place ob- stacles in the way of a too permeating police surveillance,” United States v. Di Re, 332 U. S. 581, 595. Pp. 10–29. (1) In Carpenter, this Court held that accessing cell-site location information (CSLI) constitutes a Fourth Amendment search because “individuals have a reasonable expectation of privacy in the whole of their physical movements,” 585 U. S., at 310. The Court reasoned that CSLI provides a “detailed” and “encyclopedic” portrait of a person’s whereabouts, id., at 309, and, with that, “an intimate window into a person’s life,” id., at 311. Because people “compulsively carry” their cell phones “all the time,” the Court explained, a cell phone “tracks nearly exactly the movements of its owner,” and thus “faithfully fol- lows” him not only through “public thoroughfares [but] into private residences, doctor’s offices, political headquarters, and other poten- tially revealing locales.” Ibid. The Court further observed that the “newfound tracking capacity” that CSLI gives the police “runs against everyone”—not just those “under investigation”—and “travel[s] back Cite as: 609 U. S. ___ (2026) 3
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in time,” making possible a form of surveillance that would have been unknown prior to the digital age, id., at 311–312. Carpenter accord- ingly held that “[a]llowing government access to cell-site records con- travenes” expectations of privacy. Id., at 311. Pp. 13–15. (2) Everything Carpenter relied on to find that law enforcement officers conducted a Fourth Amendment search when they accessed CSLI records applies as well or better to the police’s accessing of Loca- tion History data. First, Location History provides an even more fine- tuned picture of a person’s movements, pinpointing location within around twenty meters rather than within sectors of one-eighth to four square miles; it records location every two minutes or so for a daily average of 720 chartings rather than 101; and it can estimate elevation to reveal which floor of a building a phone is on. Second, Location His- tory allows police to reconstruct “retrospective[ly],” and with no real effort, people’s comings and goings in any area, enabling “tireless and absolute surveillance” of any number of people in any number of places. Carpenter, 585 U. S., at 312. And third, Location History im- plicates personal privacy interests even more than CSLI, because Lo- cation History is more the cell-phone user’s own. Most cell-phone users have no awareness of CSLI records, and would never try to retrieve them; by contrast, Google users regularly employ Location History as a personal journal. In that way, Location History resembles other pri- vate materials—e.g., emails, documents, photographs, or calendars— that even if stored on Google’s servers, a user reasonably views as his own and expects to be shielded from the “inquisitive eyes” of the gov- ernment. Id., at 305. Pp. 16–18. (3) The Government’s argument that accessing only a short amount of cell-phone location information does not count as a Fourth Amendment search fails. “[E]ven short-term monitoring” can provide “a we
Why this matters
A Supreme Court ruling on geofence warrants sets nationwide constitutional guardrails on how law enforcement may obtain fine-grained location data from technology providers, directly affecting the privacy interests of every bystander whose device is present near a crime scene. For the Civil Rights area, the decision shapes the Fourth Amendment baseline for digital-era searches and interacts with broader debates over the third-party doctrine, mass surveillance, and due-process protections in criminal proceedings that rely on provider-held data.