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Supplement
No. 05
Published June 30, 2026
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Subject matter
Fourth Amendment
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Chatrie v. United States
No. 25-112
Decided June 29, 2026
Vote 6–3
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Status as of June 30, 2026 · Judgment vacated and remanded to the Fourth Circuit
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On June 29, 2026, the Supreme Court held that police conducted a Fourth Amendment search when they obtained Okello Chatrie’s Google “Location History” data through a geofence warrant, because an individual has a reasonable expectation of privacy in records of his cell phone’s location. The Court vacated the judgment of the Fourth Circuit and remanded the case.1
The ruling matters because prosecutors can no longer start by arguing that this kind of geofence demand falls outside the Fourth Amendment. The next fights are about whether the warrant was valid and what happens if it was not. The Court decided one question and only that question: whether acquiring the data was a search. It had granted review limited to that issue, and it expressly declined to decide whether the warrant was valid or whether the evidence must be suppressed.3 Those questions now return to the Fourth Circuit.11
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May 20, 2019 |
A man robbed the Call Federal Credit Union in Midlothian, Virginia, taking about $195,000 at gunpoint. Witnesses and surveillance showed that the robber had approached from a corner of an adjacent church while appearing to talk on a cell phone, but officers could not identify him.4
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June 14, 2019 |
Roughly three weeks after the robbery, a detective applied to a Virginia magistrate for a geofence warrant directed to Google. The application described Location History—the Google service that records a phone’s location every two minutes or so—and drew a geofence with a 150-meter radius around the credit union.5
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The Three Steps |
Step one: Google produces anonymized location data for all phones in the geofence, 30 minutes before to 30 minutes after the robbery. Step two: officers narrow the list and Google adds data over a two-hour window, inside and outside the geofence. Step three: Google turns over identifying information. The process produced three users, including Chatrie.6
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March 3, 2022 |
The District Court (Judge M. Hannah Lauck) concluded that “this particular geofence warrant plainly violates the rights enshrined in [the Fourth] Amendment,” but it still denied Chatrie’s motion to suppress. The officers had relied on the warrant in good faith, the court held, so the Leon good-faith exception let the evidence in.7
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Good-Faith Exception |
Under United States v. Leon, evidence from a flawed warrant may still be admitted if officers relied on it in objective good faith. That ruling—not any finding that the warrant was valid—is why Chatrie lost below.7
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May–Aug. 2022 |
Chatrie pleaded guilty conditionally under Rule 11(a)(2), preserving his right to appeal the suppression ruling, and was sentenced to 141 months in prison. He appealed the judgment and the suppression decision to the Fourth Circuit.8
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July 9, 2024 |
A divided Fourth Circuit panel affirmed, but on different reasoning: it held that no search had occurred because Chatrie “did not have a reasonable expectation of privacy in two hours’ worth of Location History data voluntarily exposed to Google.” Judge Wynn dissented.9
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Panel: No Search |
Because it found no search, the panel never reached the warrant’s validity. It decided the threshold question—whether the Fourth Amendment applied at all—against Chatrie.9
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April 30, 2025 |
On rehearing en banc, the Fourth Circuit affirmed in a one-sentence per curiam: “The judgment of the district court is AFFIRMED.” The court split evenly, 7 to 7, on whether a search had occurred, and most judges who thought one had nonetheless applied the good-faith exception.10
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Evenly Divided |
Fifteen judges produced numerous separate writings; only Judge Gregory dissented from the judgment. The even split on the search question left the law unsettled—and set up Supreme Court review.10
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Jan.–Apr. 2026 |
On January 16, 2026, the Supreme Court granted certiorari limited to Question 1—whether the geofence search violated the Fourth Amendment—and declined to take up the separate exclusionary-rule question. The Court heard argument on April 27, 2026.3
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June 29, 2026 |
The Court held that the police conducted a Fourth Amendment search when they acquired Chatrie’s Location History data, reasoning that everything that made cell-site data a search in Carpenter v. United States “applies as well or better” to Location History, which is more precise, more comprehensive, and more the user’s own. It rejected the Government’s arguments that a short window of data is too little to count and that the third-party doctrine strips away any privacy interest.1 For police nationwide, the threshold question is now settled: obtaining this kind of location data is a search that needs a warrant—though what a valid geofence warrant must contain is left undecided.11
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What the Court Left Open |
The Court did not decide whether the warrant was valid. Whether each step met probable cause and particularity—and whether the good-faith exception still lets the evidence in—is for the Fourth Circuit on remand. This is “a court of review, not of first view.”11
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June 29, 2026 |
Justice Kagan wrote for the Court, joined by the Chief Justice and Justices Sotomayor, Kavanaugh, and Jackson.2 Justice Jackson, joined by Justice Sotomayor, concurred and would have gone further, calling the warrant’s second and third steps a “roving commission” that lacked probable cause and particularity.12
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The Line-Up |
Justice Gorsuch concurred only in the judgment, finding a search by a property-based route while rejecting the Katz “reasonable expectation” test and the third-party doctrine.13 Justice Alito, joined in part by Justices Thomas and Barrett, dissented and called the decision “advisory”; Justice Barrett also dissented separately.14
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Current Record |
| Through June 29, 2026 |
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This is one decision in one case. The Supreme Court held only that acquiring Location History data through this geofence process was a Fourth Amendment search. It did not decide whether the warrant was valid, whether probable cause or particularity were satisfied at any step, whether the good-faith exception still applies, or whether Chatrie’s convictions stand—all of which return to the Fourth Circuit.11 Separately, the Court noted that in July 2025 Google began storing Location History on users’ own devices and represents that it can no longer respond to geofence warrants seeking that data.15
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Source Record |
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Source links are public where available. PACER-only records are cited by docket or ECF number without local file links. Page numbers are PDF pages; reporter citations appear where the printed page differs.
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Copyright 2026 VORASYNC. All Rights Reserved.
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